P.1 

OAR Box 1859 

Prepped by Charmelle Mathews 

Document Number: 

77) V-C-2 

Docket Number: 

A-84-33 

Printed 11/24/200811:02:14 AM Sheet 77 of 79 
J 

RESPONSE TO TECHNICAL COMMENTS 

ON RIA FOR EPA 

PROPOSAL TO LIST SURFACE 

COAL MINES FOR NEW SOURCE REVIEW 

Contract No. 68-02-3890 

Work Assignment No. 36 

PN 3655-36 

and 

Contract No. 68-02-4394 

Work Assignment No. 13 

PN 3759-13 

I 

Prepared For 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

AIR QUALITY MANAGEMENT DIVISION 

Research Triangle Park, N.C. 27711 

P.2 

A-fl-33 

V-C-2 

Prepared By 

PEI Associates, Inc. 

5600 S. Quebec 

Suite 320B 

Englewood, CO 80111 

B -S B fl W fg 

NOV I 41989 

n 

EPAASRDQCKFT 

September 1986 

(Revised January 1989) 
P.3 

I 

L! 

CONTENTS 

Pa^e 

1.0 Introduction 1-1 

2.0 Comments and Responses on Proposed Rule Issues 2-1 

2.1 Health and Welfare Effects 2-1 

2.2 Definition of a Stationary Source 2-5 

2.3 Duplication of Regulations 2-7 

3.0 Overview of Comments and Responses on the Regulatory 

Impact Analysis 3-1 

3.1 Underestimation of Costs 3-1 

3.2 Overestimation of Costs 3-8 

3.3 Overestimation of Benefits 3-11 

3.4 Underestimation of Benefits 3-16 

4.0 Comments and Responses on Interpretations and 

Procedures for Determining Air Quality Impact 4-1 

4.1 Definition of Significant Impact 4-1 

4.2 Spacing of Receptors 4-1 

4.3 Air Quality Impact of Coal Mines 4-2 

5.0 Response Summary and Interpretation 5-1 

5.1 Summmary 5-1 

5.2 Interpretation 5-1 

References 

n 
P.4 

I 

E 

0 

TABLES 

Page 

Table 1 - Comparison of Mine Data 3-5 

Table 2 - Particulate Concentrations Annual Geometric 4-3 

Means (ug/m3) 

FIGURES 

Page 

Figure 1 - Comparison of Source/Receptor Geometries 3-9 

m 
P.5 

I 

G 

SECTION 1.0 

INTRODUCTION 

In November, 1986 EPA published its Regulatory Impact Analysis (RIA) for 

its October 26, 1984 proposal to require fugitive emissions from surface coal 

|j mines (SCMs) to be included in threshold applicability determinations under 

EPA's prevention of significant deterioration (PSD) program (EPA 1985). The 

If RIA was made publicly available and comments have been accepted on it. Public 

comments have raised various issues about the RIA. The purpose of this report 

18 is to address a variety of technical comments made regarding the RIA. 

** The RIA compared the projected costs and benefits of four alternate 

t- approaches to regulating SCMs under PSD. Alternative I (no listing) assumed 

IL that the proposed rule would not be promulgated. Alternative II would affect 

new and modified SCMs of a significant size commencing construction after the 

promulgation of the regulation. These mines would be subject to PSD review. 

Mines commencing construction prior to implementation of the regulation would 

|| not be affected. Alternative III is very similar to Alternative II, except 

that mines qualifying as major sources that commenced construction after 

H January 6, 1975 would be counted as consuming PSD increments. Consequently, 

existing mines would need to retroactively comply with the PSD requirement. 

Alternative IV would affect only new and modified mines that have ambient 

impacts on areas designated by the Clean Air Act (CAA) as having special 

scenic and ecological value. These areas are designated as Class I and 

mandatory Class II areas. 

This report presents the major technical comments submitted on the RIA 

and responses to those comments. At least one citation is offered for each 

comment. The specific comments pertain generally to those addressing the 

emission and dispersion analysis performed by PEI Associates, Inc. and 

included in the RIA. General responses to the comments concerning the 

economic analyses are included in this report. 

This report is divided into four additional sections. Section 2 

discusses comments and responses on the proposed rule issues. Section 3 

1-1 
P.6 

e 

presents comments and responses on the RIA and includes a comparison cf the 

RIA technical analyses to those performed on behalf of industry trade 

associations. Section 3 also includes comments made by environmental groups, 

Section 4 contains comment* and responses on determining the air quality 

impact of coal mines. Finally, Section 5 presents a summary and 

interpretations of the comments. 

1-2 
P.7 

g SECTION 2.0 

ra COMMENTS AND RESPONSES ON PROPOSED RULE ISSUES 

1 

This section of the report presents comments that have been received on 

[| certain basic issues pertaining to the nature and effects of SCMs. Many of 

the comments that were received on the proposed rule raised questions on the 

H applicability of the rule. Below is a summary of the key issues. The 

comments have been paraphrased from the original statements and each is 

g| followed by a technical response addressing the specific issue. 

H 2.1 HEALTH AND WELFARE EFFECTS 

Below is a summary of comments received from various organizations 

concerning health and welfare effects related to SCMs. 

p». 

I 

2.1.1 National Emissions 

COMMENT: Many of the comments noted the relatively small contribution of 

fugitive emissions from SCMs to total national particulate emissions. Citing 

a 1980 paper, several comments stated that, on a national annual average, SCMs 

represent less than one percent of all particulate emissions from open sources 

(Evans and Cooper 1980). Further, they stated that unpaved roads and 

agriculture were the largest fugitive dust sources on a national basis. 

RESPONSE: The 1976 national inventory performed by Evans and Cooper, 

presents an unrealistic evaluation of coal mines. It is not appropriate to 

consider national emissions when evaluating the local impact of mining 

sources. Any national inventory does not take into account the geographical 

distribution of mines. Due to the location of the resource, mines tend to be 

clustered around a primary coal seam. Consequently, an inventory with a finer 

resolution (smaller geographic area) may show that coal mines are a 

significant source in certain locations. Also, the 1976 inventory does not 

fully account for the increased level of mining activity in recent years. The 

2-1 
P.8 

D 

D 

increase in the number and production of mines in the Powder River Basin since 

1976 is just one example. 

Calculated particulate emissions for any given mine are large. For 

example, annual particulate erissions from the five mines evaluated in the RIA 

ranged from 644 to 4,117 tons/year. Similar calculations performed by a 

contractor for four other mines ranged from 1,404 to 15,454 tons/year (TRC 

1985). Consequently, even though SCMs may represent a small fraction of total 

national emissions, any given mine may be a significant local source. 

Finally, it is somewhat incongruous to compare intermittent dispersed 

sources, such as unpaved roads and agriculture to a coal mine which operates 

24 hours/day and whose emissions are concentrated in a relatively small area. 

Again, it is not appropriate to compare total national emissions to the 

potential local impact of mining sources. Total annual national emissions may 

bear little relationship to the local impact if a smaller geographic area and 

a 24-hour time frame are considered. 

COMMENT: Several comments stated that coal mines are generally located 

in sparsely populated areas and therefore have a minimal air quality impact. 

RESPONSE: The fact that mines may not affect a large population is not 

particularly important. The PSD rules do not consider population impact. In 

addition, the RIA showed that the air quality impact from a mine may be quite 

substantial. 

The local impact from mines may be substantial and not only impact 

population centers but also impact Class I areas such as national parks. 

Also, the emissions from the mines are generally concentrated over a 

relatively small geographic area, unlike the emissions from rural unpaved 

roads and agriculture which are spread over large areas. Consequently, the 

air quality impacts of SCMs can not be dismissed as minimal. 

2.1.2 Particle Size 

COMMENT: A number of comments concerned the particle size distribution 

of SCM emissions. Specifically, coarse particles that rapidly fall out of the 

plume represent a substantial mass of the emissions (EPA 1986). Another 

comment noted that a single particle the size of a grain of sand (roughly 2500 

micrometers) would be sufficient to cause an exceedance of the PSD increments 

(MARC 1984). 

2-2 
P.9 

1 

I 

RESPONSE: Mining emissions are composed of substantial numbers of coarse 

particles. Although sand particles could theoretically contribute to measured 

excursions above the NAAQS or PSD increments, it is unlikely that any 

particles of this size would be measured beyond the fenceline. Rather, smaller 

particles would be measured. In the RIA analyses, only particulate emission 

factors representing 30 micrometer and smaller particles were used to estimate 

SCM emissions. Consequently, larger particles emitted at the source are not 

reflected in the SCM emission estimates contained in the RIA. 

The original research data referenced in the comments was based on 

microscopic analysis of open-faced filter samples collected near the sources 

(EPA 1974). These data showed the presence of large particles near the 

source. The results are not directly comparable to the methods used in the 

RIA, as noted above, nor are they related to the EPA's ambient measurement 

methods for particulate matter. EPA's current ambient measurement method for 

particulate 10 micrometers and smaller (PM,n) physically excludes the larger 

particles discussed above. Consequently, the presence of large particles at 

the sources has little impact on the resulting off-site measured 

concentrations. 

Predicted excursions above the NAAQS or PSD increments in the RIA are due 

to the magnitude of the emission estimates not the presence of large 

particles. Based on a previous study (EPA 1982), attainment of the PM,~ NAAQS 

may be a problem for SCMs, even though the sampling method excludes the large 

particles discussed in the comments. 

2.1.3 Comparison of NAAQS and Worker Exposure Limits 

COMMENTS: Some of the comments referred to the threshold limit value 

3 

(TLV) for nuisance particulates for workers (10,000 ug/m ) and compared this 

value to the PSD increments and the NAAQS (EPA 1986). 

RESPONSE: The TLV for worker exposure to nuisance particulates has been 

developed for use in the practice of industrial hygiene as guidelines or 

recommendations for control of potential health hazards in the workplace. 

They have been developed for a population of healthy, non-smoking, adult 

workers for a normal 8-hour workday and a 40-hour workweek. The TLV listed 

above represents total dust containing no asbestos and less than one percent 

2-3 
P.10 

F. 

free silica. The TLVs are not intended for use in evaluating or controlling 

community air pollution nuisances, or continuous, uninterrupted exposures 

(ACGIG 1988). These limitations also apply to measured or predicted 

concentrations of particulate downwind of a SCM. 

It is inaccurate to compare the TLV for worker exposure to nuisance 

particulates to the NAAQS for the population as a whole. The general 

population not only includes healthy workers but also small children, the 

elderly, and people with health problems. The NAAQS are designated to protect 

the most sensitive segment of the population with a degree of safety. In 

addition, the NAAQS reflect potential for longer-term exposure, rather than an 

8-hour workday. Also, workers exposed to nuisance dusts are provided with 

personal protective equipment, the general population is not. 

Since the TLV for nuisance dust is unrelated to the NAAQS and the PSD 

increments, the TLV should not be included as a consideration in the 

rulemaking process. 

2.1.4 Visibility Impacts 

COMMENT: Only a small fraction of the fugitive emissions are fine 

particles of the size which impair visibility. 

RESPONSE: A previous response addressed the comment that fugitive 

emissions are primarily coarse particles that rapidly fall out of the plume by 

saying that only emission factors representing 30 micrometers and smaller 

particles were used to estimate surface coal mine emissions. In addition to 

that response, it should be noted that although fine particles (2.5 

micrometers and smaller) are most efficient (for their mass) at scattering 

light and thereby impairing visibility, larger particles suspended in the 

atmosphere also impair visibility. (U.S. EPA 1979) 

COMMENT: The worst case visibility impairment predicted for Bryce Canyon 

was predicted to occur at night in the winter when there would be no visitors 

present. 

RESPONSE: This RIA does suggest that this predicted worst case situation 

would not have any significant effect on park visitors, but the benefits 

estimates developed for Alternative IV were based on the average change in 

2-4 
P.11 

D 

visual range, not the worst case. 

COMMENT: Chaco Culture National Historic Park was established to 

preserve the activities of earlier man, not as a wilderness preserve, so 

evidence of a surface coal mine would not be repugnant. 

RESPONSE: The primary purpose of the park being historic preservation 

does not preclude that visibility may be important to park visitors. For 

example, two Class I areas that have been listed by the National Park Service 

as having visibility as an important value are Mesa Verde National Park and 

Bandelier National Monument, both are parks where preservation of 

archeological remains is the primary purpose. 

2.2 DEFINITION OF A STATIONARY SOURCE 

2.2.1 Source Location 

t- COMMENT: Many comments discussed the fact that coal mining is a dynamic 

operation with no well-defined emission location. Therefore, mines should not 

j be classified as stationary sources (EPA 1986). 

RESPONSE: Coal mines are non-traditional sources. They bear little 

relationship to more conventional "smoke stack" major stationary sources, such 

as power plants. However, the lease areas of coal mines are well established, 

ll Clearly, Congress intended for SCMs to be considered as stationary sources, 

® since the only mobile sources specifically separated from stationary sources 

under Title II of the CAA are motor vehicles and aircraft. Therefore, SCMs 

E3 

G are considered to be stationary sources by EPA and no change in the definition 

is being considered at this time. 

COMMENT: Some comments noted that the location and configuration of the 

operations are continually changing. Therefore, SCMs are temporary sources. 

RESPONSE: Given that the life expectancy of many mines is 25-40 years, 

it is difficult to consider them to be temporary sources. A typical, 

"permanent" power plant usually has a design life expectancy of 40-50 years. 

Additionally, the lease area of a mine may increase several times, extending 

the mine life. Therefore, SCMs should not be considered to be temporary 

sources. 

2-5 
P.12 

i 

D 

1 

2.2.2 Definition of Source Modification 

COMMENT: Some comments expressed concern about how a modification to an 

SCM will be treated, since many of the operational changes that occur over the 

life of a mine will result in increased emissions (i.e. adding haul roads). 

RESPONSE: The intent of the definition in Section 111(a) of the CAA is 

that only a significant change in operation, such as a production increase, 

which results in a substantial increase in emissions would be considered a 

modification. In the case of SCMs, increased production, extending haul 

roads, increased overburden thickness, or a change in the mining plan could 

result in substantial increases in emissions. Further study of this question 

by EPA is needed to establish an appropriate definition for SCMs. One option 

to consider would be to define an emission ceiling for a mine based on 

worst-case predicted emissions over the life of the mine. This ceiling could 

be incorporated into the permit. Any change in operations causing emissions 

to exceed this ceiling could be considered under the revised definition of a 

major modification. This question would need to be addressed prior to final 

promulgation of the rule. 

2.2.3 Definition of Secondary Emissions 

COMMENT: One set of comments argued that EPA should exclude secondary 

(mining related) emissions, such as emissions from haul truck traffic, since 

dust generated by traffic on-site does net constitute an emission of the mine 

itself (Dineh 1986). 

RESPONSE: Logically, all operations at an SCM are directly related to 

the surface mining of coal. For example, overburden removal must occur to 

expose the coal seam and the trucks must transport the coal to the coal 

preparation facility for processing. As part of the RIA, the entire coal 

mining process was treated as a single facility, since off-site particulate 

concentrations are directly related to emissions from all sources not just a 

few. These off-site concentrations were used for comparison to the NAAQS and 

the PSD increments. 

2-6 
P.13 

11 

•:l 

fl 

2.3 Duplication of Regulations 

COMMENT: Several comments argued that PSD regulations for SCMs would be 

duplicative of other pre-existing environmental regulations and authorities, 

and thus unnecessary, costly and of no additional benefit. Regulations and 

authorities mentioned included BACT, PM NAAQS, authorities allowing DOI to 

declare lands unsuitable for surface mining, and NEPA EIS requirements. 

RESPONSE: All costs and benefits are measured relative to a baseline 

level of air quality expected to exist under Alternative I where SCMs are not 

subject to PSD regulations. The RIA explicitly assumed PM NAAQS compliance in 

the baseline. Thus, there is no duplication with PM NAAQS. 

The RIA characterizes PSD, in part, as extending BACT to SCMs. It is 

appropriate for the RIA to estimate the costs and benefits of extending BACT 

^j to SCMs which would not have otherwise been subjected to BACT requirements, 

2-7 
P.14 

iM 

I 

I 

SECTION 3.0 

OVERVIEW OF COMMENTS AND RESPONSES ON THE REGULATORY IMPACT ANALYSIS 

In general, the comments stated that the RIA overestimated the benefits 

and underestimated the costs of the regulatory alternatives. The opposite 

opinion was stated in a few comments. This section mainly compares the 

technical analysis performed by PEI with those performed by another consultant 

on behalf of the coal interests. 

3.1 UNDERESTIMATION OF COSTS 

COMMENT: Several comments enumerated the potential adverse economic 

impacts of the PSD regulations: loss of some developable coal reserves; higher 

prices to consumers for fuel and electricity; and loss of jobs, tax revenues, 

and royalties to counties, states and the federal government. 

RESPONSE: The cited impacts are primarily distributional impacts, rather 

than true economic losses (e.g., GNP reductions). Coal reserves lost in one 

area may be offset by reserves of comparable cost and quality elsewhere. In 

that case production may shift from one location to another, but production 

would occur nonetheless. Likewise, jobs, taxes and royalties may be reduced 

in one area, but increased a corresponding amount in the other areas to which 

production shifts. Higher electric prices for distant consumers enable SCM 

populations to experience improved health, reduced soiling, etc. If benefits 

of PSD regulation exceed costs (i.e., there are net economic gains), then at 

least in principle it would be possible for gainers to compensate losers so 

that all are better off. 

COMMENT: The RIA's assumption that each regional coal basin is an 

independent market was criticized by industry commenters. They claimed that 

this assumption would cause economic impacts to be understated because it 

would underestimate the extent to which production would shift among regions. 

3-1 
G 

G 

I 

RESPONSE: The assumption could also cause costs to be overstated, 

because it restricts substitution possibilities. That is, rather than 

continuing to produce from mines whose costs are increased by PSD regulations, 

it may be less costly to import lower cost coal from other regions. The 

latter possibility would be ignored by the assumption of regionally 

independent markets. 

Similarly, the RIA's estimates of electricity price increases may be 

overstated because increased substitution of oil and gas for coal as a fuel in 

electric power generation was not considered. 

COMMENT: The RIA was criticized for assuming a constant national coal 

supply elasticity across all production ranges. 

RESPONSE: Separate supply elasticities were used for deep coal, surface 

coal in Appalachia, surface coal in the midwest and surface coal in the west. 

However, within a given region, a constant elasticity was assumed. 

3.1.1 Mine Size 

COMMENT: Several comments stated that the sizes of the prototypical 

mines (production) used in the RIA were too small (NCA 1986). Consequently, 

the cost figures may be too low. Conversely, the Sierra Club stated that the 

RIA used the largest mines in the regions and the cost figures were too high. 

RESPONSE: For the purpose of the RIA, it was EPA's opinion that 

evaluations of the smallest or largest mines in an area would not represent an 

accurate characterization of mining impacts. Given realistic budget 

constraints, it was not feasible to evaluate a range of mine sizes. 

Therefore, prototypical mines were selected based on the average annual 

production for a given area. 

By using the average mine for an area, the cost figures for the control 

options may be understated for the largest mines and overstated for the 

smallest mines. In the absence of results for both the smallest and largest 

mines, it is impossible to determine the degree of accuracy for the cost 

estimates at the extremes of the range of production. It is felt that the 

average mine size used in the RIA represents a reasonable estimate for the 

population of mines in a given area. As is true for any average value 

3-2 
P.16 

analysis, results may not be totally appropriate at the ends of the range. 

I However, the analysis performed in the RIA represents a reasonable estimate 

1 for the mining regions as a whole. 

1 3.1.2 Meteorological Assumptions 

COMMENTS: Several comments stated that the air quality analyses in the 

O

RIA did not consider absolute worst-case 24-hour meteorological conditions. 

The RIA included only C and D stability classes, while analyses performed by a 

p, consultant on behalf of the coal interests used C, D, E, and F stabilities 

| (TRC 1985). 

G 

fe 

RESPONSE: The analyses performed by the coal interests' consultant 

encompassed a broader range of meteorological conditions than the RIA did. It 

is true that the data used in the RIA do not include the absolute worst-case 

_ meteorological conditions. That is, those conditions which have little 

likelihood of occurring in mining areas. The RIA data are representative of 

£.-• persistent worst-case meteorology that may occur in these areas. 

The choice of meteorological conditions directly affects the resulting 

j predicted concentrations. However, it is the combination of short-term 

meteorology and emissions that dictates the actual off-site concentrations. 

As part of the RIA, three combinations of meteorology and emissions were 

considered: worst-case meteorology and average short-term emissions, average 

meteorology and worst-case short term emissions, and worst-case meteorology 

and emissions. Two of these options were rejected for several valid reasons. 

In the case of the first option, worst-case meteorological conditions 

occur on only a ^ery few occasions over the course of a year. On those few 

occasions it is unlikely that the most stable conditions (stability classes 

D,E, and F) would persist for 24-hours. These worst-case meteorological 

conditions may also be associated with lower emissions. For example, 

rainfall, snow, or air stagnations may be associated with the worst-case 

meteorological conditions and would tend to reduce emissions at the same time. 

In addition, using average emission conditions does not accurately portray 

worst-case emissions that may frequently occur. 

In the case of the third option, the probability that worst-case 

meteorological conditions and worst-case emission conditions would occur in 

the same 24-hour period is practically zero. Given the low relative frequency 

3-3 

G 
P.17 

I 

1 

of occurrence of worst-case meteorological conditions and the probable effect 

of short-term emissions being lower on these days, it was not appropriate to 

select this option. The second option was the logical choice. 

Peak short-term emissions are expected to occur on multiple occasions. 

The persistent meteorological conditions assumed for the analysis would also 

occur frequently. This combination represented the best estimate for 

predicting the maximum off-site impact from the prototypical mines. 

3.1.3 Emission Factors 

COMMENT: Some comments argued that since as many as 50 percent of the 

RIA emission factor data points were assumed, the factors are unreliable 

(Montana Coal Council 1986). In addition, since the emission factors were 

developed for western SCMs they were inappropriate for use at midwestern and 

eastern locations. 

RESPONSE: In the original reference for the emission factors (EPA 1981), 

problems were noted with the fine particulate (FP< 2.5 micrometers) 

concentrations. For cases where net downwind concentrations were negligible 

(i.e. zero), a minimum detectable mass was substituted for the actual mass 

value. The resulting FP concentrations were very close to zero. This 

substitution was needed for the logarithmic extrapolations used in the 

emission factor development, since the logarithm of zero is undefined. This 

substitution had the effect of artificially raising the ££ concentrations 

about 10 percent. The substitution had no effect on TSP concentrations or 

emission factors. Since the FP emission factors were not used in the RIA, 

this substitution had no effect on the results. 

Although no emission factors have been developed for areas other than the 

west, no other data are available. The emission factors have been applied to 

midwestern and eastern mines in the absence of other appropriate data. The 

actual emissions from these mines may be lower than those predicted with the 

emission factors due to different climatological conditions (i.e. more rain, 

higher relative humdities). There is ample precedence for this approach based 

on the use of AP-42 emission factors. Emission factors in this document are 

based on limited field data and are routinely used for other sources. 

3-4 
P.18 

m 

i 

3.1.4 Industrial Source Complex (ISC) Model 

COMMENT: A number of comments noted deficiencies in the ISC model as 

applied to SCMs (Montana Coal Council 1986). 

RESPONSE: There are some well documented analyses that have been 

performed on the ISC model (TRC 1985a,b). These analyses have shown that 

there are both systematic and random errors associated with the use of the 

model. However, this model is currently the preferred method for coal mine 

analyses. In the RIA, the model was applied consistently. Although the 

results may not be correct in an absolute sense, the results are valid for 

relative comparisons. 

3.1.5 Affect on Existing Mines 

COMMENT: Several comments stated that the RIA erroneously assumed that 

no existing mines would be affected by listing SCMs near Class I and mandatory 

Class II areas. Then, several examples were given of mines near Indian 

reservations (Class II areas) to demonstrate the point (EPA 1986). 

1 RESPONSE: The analysis of Alternative IV was restricted to national 

parks. No consideration was given to Indian reservations. Consequently, the 

I . costs and quantity of lost reserves for Alternative IV were underestimated. 

This omission would have a substantial impact on the estimates of lost 

p reserves if coal mines are listed. However, if estimated on a national basis, 

benefits would likewise be increased by including mines on Indian 

I., reservations. But, without actually performing a national benefit-cost 

analysis, it is not possible to say whether net benefits would increase, 

Fj decrease or stay the same. 

U 3.1.6 Industry Studies 

Several industry trade associations (NCA 1986) contracted with a 

fp consultant to examine the air quality impacts of a hypothetical mine in each 

"' of six coal basins (TRC 1985b, 1985c, 1985d). The consultant effectively 

i followed the basic analysis process used in the RIA; however, there were some 

substantive differences in methodology and results. For the purposes of this 

comparison, the consultant's report for four hypothetical mines and the four 

similar mines evaluated in the RIA are used. 

3-5 
P.19 

Table 1 contains a summary of data for mines analyzed by TRC and for 

those included in the RIA. The first basic difference is in the production 

level assumed for each hypothetical mine. The RIA used average size mines for 

r each area, while the TRC analyses used larger mines for three of the four 

BB basins. There were a few minor differences in emission calculation procedures 

„~ in the two studies. However, these differences were inconsequential compared 

If to the differences in control efficiencies used. For example, the RIA assumed 

99 percent control for paved access roads, whereas, TRC used 50 percent 

|J control for chemical dust suppression. 

This difference in basic assumptions resulted in substantial differences 

KJ in calculated emissions. For example, in the San Juan Basin mine the lightand medium-duty vehicle emissions that TRC calculated were almost 7,000 

P tons/year greater than in the RIA. 

" Another basic difference was the control efficiency for temporary roads. 

P

TRC assumed no control and the RIA used 50 percent control for watering. These 

different assumptions coupled with the different production levels account for 

( most of the differences in calculated emissions. The remaining differences can 

j be traced to different mining parameters used in the two analyses. 

The differences noted above reflect the variability in technical approach 

|| permitted by existing methodologies. Until many of the parameters are 

standardized, no consistent set of results can be obtained. Also, in generic 

H studies of this type, the definition of the prototypical mines is subject to 

the judgement of the analyst performing the evaluations. In this case, even 

if both analyses had used the identical mines, substantial differences in 

-* results would still have resulted due to selection of the control 

0

efficiencies. 

The next difference between the studies centers around the 

production/pollution algorithm. Both studies made the basic assumption that 

If TSP emissions are directly related to production. The RIA carried the 

equivalency further, based on the mathematical formulation of the basic 

m dispersion equation contained in the ISC model. 

3-6 
P.20 

fl 

Kl P 

TABLE 1. COMPARISON OF MINE DATA 

Coal Basin 

Powder River 

San Juan 

Illinois 

Appalachian 

Annual Production 

IO6 Tons 

RIA 

10 

5 

1.5 

0.5 

TRC 

15 

10 

3 

0.5 

TRC/RIA 

1.5 

2.0 

2.0 

1.0 

Annual TSP Emissions 

Tons/Year 

RIA 

1418 

4117 

1854 

644 

TRC 

2,399 

15,454 

7,444 

1,404 

TRC/RIA 

1.7 

3.8 

4.0 

2.2 

I 

3-7 
P.21 

I 

Ila a u 

y z 

(Equation 1) 

Where x = concentration 

Q = emission rate 

o a = standard deviations of plume concentration 

u = wind speed 

The RIA assumed that all variables in Equation 1 remained constant except 

for emission rate (Q). If emissions decreased by 50 percent, then the 

concentration must decrease by 50 percent. Consequently, there was no need to 

remodel the smaller mines calculated from the production/pollution algorithm. 

All lease boundaries, source locations, receptor locations, and meteorological 

conditions were constants. 

The consultant, on the other hand, interjected additional assumptions 

into their analyses. First, they did not use a defined lease boundary. 

Receptor locations were selected on the basis of good modeling practices for a 

particular source/receptor combination. Second, they assumed that as 

production decreases so did the source sizes. Consequently, they also changed 

the source/receptor geometry. This situation is presented graphically in 

Figure 1. The figure is a simplification; however, it does show the 

differences in approach. The consultant has not demonstrated that the RIA 

methodology is inappropriate or incorrect. Rather, they have used a different 

set of assumptions to arrive at a different answer. If the receptors had been 

placed cn the lease boundary for their first model run, then on the second 

model run, they were effectively moved inside the boundaries. There is 

nothing necessarily wrong with their assumptions. If production decreases, it 

^ may be true that both the source area and the lease area would shrink. 

Consequently, the consultant's methodology and emission calculations showed 

that mines, substantially smaller than those determined in the RIA, would meet 

the PSD increments. 

3.2 OVERESTIMATION OF COSTS 

COMMENT: In contrast to the industry comments, one set of comments 

claimed that the RIA had overestimated the costs of listing SCMs (Sierra Club 

3-8 
BASE CASE 

RIA 

1 

1 

1 

1 

• 

i 

i 

i 

Source -- Size = 1 

Emission Rate = Q 

Receptor Distance = 1 

TRC 

Source -- Size = 1 

Emission Rate = Q 

Receptor Distance = 1 

REDUCED PRODUCTION CASE 

I RIA 

"1 

i 

i 

i 

Source -- Size = 1 

Emission Rate = i Q 

Receptor Distance = 1 

TRC 

Source -- Size = 0.7 

Emission Rate = i Q 

Receptor Distance = 0. 

Figure 1. Comparison of Source/Receptor Geometries 

3-9 
P.23 

1986). The basic thrust of their comments was that additional emission 

controls would eliminate the problems discussed in the RIA and in the industry 

comments. The controls that they proposed include: 

1. Paving all haul roads. 

2. Speed restrictions on unpaved roads. 

3. Traffic restrictions. 

4. Stabilize all exposed areas. 

5. Cover haul trucks. 

6. Use conveyor systems rather than haul trucks. 

7. Reduce time soil is exposed. 

8. Reduce pit size. 

RESPONSE: Paving the haul roads is a control measure that would result 

in reduced emissions but cause no reduction in production. However, the cost 

of paving and road maintenance for a road capable of handling large haul 

trucks is likely to be very high. The road would need to be equivalent to an 

interstate highway or an airport runway. In addition, some continuous 

construction and demolition of roads would be required as the pit changed 

location. 

Similar arguments would be used for conveyor systems, which if 

cost-effective would be in broader use. 

Speed restrictions and traffic restrictions would reduce production. For 

example, if vehicle speed was reduced 50 percent, the production would be 

reduced 50 percent or twice as many haul trucks and drivers would be required. 

Covering the haul trucks has some potential benefits. Emissions from 

coal dust blowing from the trucks would be reduced. In addition, coal 

spillage from the trucks would be reduced or eliminated, possibly reducing 

emissions from the unpaved haul roads. On the other hand, additional personnel 

and/or time would be needed to cover and uncover the trucks. Again, if this 

method were cost-effective, it would be employed in the industry. 

Other techniques for unvegetated areas are included in various 

reclamation regulations under the Surface Mining and Reclamation Act (SMCRA) 

administered by the Department of the Interior (DOI). 

COMMENT: The Sierra Club also stated that the RIA and industry studies 

assumed that haul road emission remained constant as production decreased, 

resulting in cost estimates for control that were too high. 

3-10 
P.24 

G 

1 

RESPONSE: As discussed in the previous sub-section, both the RIA and the 

industry studies assumed a linear relationship between haul road emissions and 

production. If production decreased by 50 percent, then the emissions were 

assumed to decrease by 50 percent. 

COMMENT: The Sierra Club also stated that since the RIA used the largest 

mines in each region for predicting cost, the cost estimates were too high. 

RESPONSE: As discussed previously, the RIA used average mine sizes in 

each of the five coal basins. 

3.3 OVERESTIMATION OF BENEFITS 

COMMENTS: Many comments stated that the RIA overestimated benefits from 

controlling SCMs in the vicinity of the Class I areas at Bryce Canyon because 

it ignored the fact that a significant portion of the benefit was realized by 

the DOI's unsuitably determination (NCA 1986). 

RESPONSE: The Class I and mandatory Class II analyses in the RIA were 

meant to be generic in nature as were the analyses for the other alternatives. 

The unsuitability determination was not considered in the analysis so that the 

results could be extrapolated to other areas. For the purposes of the RIA, 

all benefits that were realized were assumed to be for a generic mine for 

which no previous analyses had been performed. 

COMMENT: Several comments stated that EPA failed to consider the adverse 

effects that a listing decision would create because of its incentive to 

develop more, smaller SCMs. 

RESPONSE: Smaller coal mines produce more particulate and disturb a 

larger surface area per ton of coal mined than larger mines. In this respect, 

the actual benefits of listing SCMs may have been overestimated. Some 

economies of scale are realized with larger mines, resulting in lower 

emissions per ton of coal produced. 

COMMENT: Several commenters argued that there would be no benefits from 

PSD review of SCMs because such review is required in areas in which air 

quality is already better than NAAQS, and the NAAQS are supposed to be set at 

levels below which there are no known adverse health or welfare effects. 

3-11 
P.25 

fl 

[ 

E 

RESPONSE: A previous EPA study, (1982) found that SCMs may have 

difficulty complying with the PM.n NAAQS. Thus, the assertion that SCM air 

quality is better than the NAAQS is open to question. Furthermore, it is not 

necessarily the case that there would be no benefits from improving air 

quality beyond NAAQS. A quote from the 1987 Federal Register notice for the 

PM,0 NAAQS illustrates this point: "The intent of the margin of safety 

requirement was to direct the Administrator to set air quality standards at 

pollution levels below those at which adverse health [and welfare] effects 

have been found or might be expected to occur in sensitive groups. Experience 

with the requirement has shown that the scientific data are often so 

inconclusive that it is difficult to identify with confidence the lowest 

pollution level at which an adverse effect will occur. Moreover, in cases 

such as the present one, the evidence suggests that there is a continuum of 

effects, with the risks, incidence, or severity of harm decreasing, but not 

necessarily vanishing, as the level of pollution is decreased." The latter 

point in this quote was at least partly illustrated by the relatively small 

benefit measures obtained from the analyses of Alternatives II and III in the 

RIA. 

COMMENT: A series of comments argued that SCM fugitive dust consists 

primarily of large, inert, non-toxic particles which differ from the particles 

present in urban areas that are the basis for most of the health and welfare 

effects studies available. Consequently, application of these studies to 

calculate health and welfare effects near SCMs would lead to large 

overestimates of effects, and thus overestimates of the benefits of PSD 

regulation. 

RESPONSE: The PM,„ standards focus on particulate matter capable of 

penetrating to the sensitive thoracic region of the respiratory tract. While 

toxicity of various particles may differ, the exhaustive review of the 

available health effects information supporting the PM.Q standards suggests 

that all particles within this size range are of concern. Moreover, it is not 

clear that coal dust, (which must be a constituent of surface coal mine 

emissions,) per se is nontoxic. Indeed, coal dust may contain toxic 

impurities, such as metals. In any event, "inert" particles may be 

responsible for a variety of health effects, from deposition throughout the 

respiratory tract and by several possible mechanisms (review of NAAQS for 

3-12 
P.26 

B 

I 

Particulate Matter, Staff Paper, EPA-4501, 5-82-001, January, 1982, pp. 29-39, 

and Table 5-2). For example, nonspecific irritation in the tracheo-bronchial 

region may alter respiratory function or clearance mechanisms, clearly of 

health concern, particularly for sensitive subgroups of the population (j.g., 

asthmatics, elderly, persons with chronic respiratory disease). 

COMMENT: The visibility benefits are flawed because they are based on 

results of willingness to pay studies, which are inherently biased because 

respondents exaggerate their responses when they do not actually have to pay. 

RESPONSE: This assertion is often made or assumed with regard to 

willingness to pay studies, but empirical proof is lacking. In fact, there is 

some evidence to the contrary (Cummings et al. 1986 and Mitchell and Carson 

1988). Comparisons between contingent valuation results and market studies 

involving actual payments do not support the hypothesis that contingent 

valuation studies are consistently upward biased. There is evidence that 

contingent valuation results are subject to various potential biases and 

influences that can cause considerable error and uncertainty in the results, 

but the direction of bias can be either upward or downward depending on the 

specifics of the study design. 

COMMENT: Using the $2.84 value from the Rae (1983) study for a clear 

versus moderately hazy view at Mesa Verde National Park is not valid because 

it is being applied to a different park (Bryce Canyon National Park) and 

because the estimated change in visual range for Alternative IV is very small 

and could not be characterized as the difference between clear and moderately 

hazy. 

RESPONSE: It is true that there is considerable uncertainty in applying 

estimates obtained for one park to another park, but in the absence of 

estimates obtained specifically for Bryce Canyon, it is reasonable to apply 

estimates obtained at Mesa Verde. First of all, both of these national parks 

are in the southwest with similar visibility conditions with regard to 

background levels of visual range. Second, there are several such studies 

that have been conducted at southwestern parks (Rowe el al. 1980; Schulze et 

al. 1981; and MacFarland et al. 1983) and all have found roughly similar 

estimates for this type of change in haze conditions (ranging from about $1 to 

$4). The evidence that comparable estimates have been obtained for several 

3-13 
P.27 

G 

n 

t 

§ 

parks in the southwest supports the assumption that similar values could be 

expected for Bryce Canyon as well. 

The second part of this comment that the change in visual range 

predicted for Alternative IV is much smaller than the moderate haze to clear 

change depicted in the Rae study is valid, but the comment fails to 

acknowledge that this was used as an upper bound estimate in the RIA. A 

lower estimate was also obtained based on a per mile change in visual range. 

This upper bound estimate is also supported by the results obtained with 

regard to visible plumes in several of these studies at southwestern parks. 

Per day values of about $2 tc $5 were given at Mesa Verde and at the Grand 

Canyon for the prevention of an emission plume visible from the park. The RIA 

does not consider whether the emissions from a surface coal mine would be 

comparable to the plumes considered in these studies, but it is possible that 

these values would be applicable. 

COMMENT: The Randall Study (1978) concerning the visual aesthetics of 

eastern surface coal mines was used without qualification and overstates the 

benefits of preventing surface coal mines being visible from a national park 

in the west because (1) the aesthetic damage for a resident is not related to 

that for a park visitor, (2) values obtained by Randall for households were 

applied per individual visitor, and (3) there are differences between mines in 

Appalachia and western Class I areas. 

RESPONSE: It is not accurate to say that the Randall study was used 

without qualification. Reasonable qualifications about uncertainties in 

applying the results of this study to this RIA are included in the text. The 

points of concern given in the comments are valid, but only one (#2) 

necessarily implies that the estimates overstate the benefits of Alternative 

IV. This assertion was investigated and was found to be correct. However, 

re-estimation of the net benefits (by reducing this benefit category by two 

thirds) of Alternative IV reveals that there would be no change in the 

conclusions presently made in the RIA. 

Conversely, benefit estimates in the RIA may be understated. The RIA 

argues that the estimates based on the Randall study are likely to be 

understated rather than overstated because per day values are likely to be 

higher for park visitors who are visiting the site only for a few days than 

for local residents who are giving monthly estimates. This argument is 

3-14 
P.28 

fl 

G 

I 

supported by the results of Rowe et al. (1980). Visitors at Lake Powell gave 

estimates of $2.50 to $4.00 per day to prevent different levels of visibility 

degradation while local residents gave $3.50 to $6.50 per month to prevent the 

same degradations. 

The third point that the circumstances of a resident near a surface coal 

mine in Appalachia are different from a western Class I area visitor 

seeing a surface coal mine from the park is correct. There are many 

uncertainties in applying results from the former to the latter, but it is not 

clear whether upward or downward bias is involved. 

COMMENT: The extrapolation of existence values from the Grand Canyon 

study is invalid because Bryce Canyon is not the same class of "natural 

wonder" as the Grand Canyon and because there is no basis for the adjustment 

according to park visitation rates. 

RESPONSE: The RIA acknowledges that the existence value estimate based 

on the Southwest Parklands study (Schulze et al. 1981) is highly uncertain and 

that this estimate was not used in the calculation of net benefits for 

Alternative IV. The Southwest Parklands study was not only about the Grand 

Canyon, but about all the parks in the Southwestern region. Substantial 

preservation values were given for protecting visibility at parks in addition 

to the values for the Grand Canyon. While the results do not provide per park 

values for other parks in the region, it is clear that preservation values for 

these parks are substantial. It is true that the adjustment cf the Grand 

Canyon values by the ratio of park visitation at Bryce versus Grand Canyon is 

arbitrary, but it was made as an effort to acknowledge that Bryce is less well 

known and maybe less of a "natural wonder" than the Grand Canyon. Visitation 

is one reflection of these differences. 

COMMENT: The existence value estimates fail to consider the temporary 

nature of a surface coal mine and any associated visibility degradation. 

RESPONSE: The existence value estimates were based on responses to 

questions about willingness to pay on a per year basis to prevent a specified 

degradation in visibility conditions. The time horizon was not specified but 

the cause was described as manmade air pollution such as from power plants. 

No such air quality changes are necessarily permanent. Whether annual 

willingness to pay estimates would be different if an impact were to be 

3-15 
P.29 

1 

I 

I 

I 

expected for a few years as opposed to a few decades is an empirical question 

that has not been addressed. Given available information, the results of 

previous studies were not inappropriately applied in the RIA. 

3.4 UNDERESTIMATION OF BENEFITS 

COMMENT: The Sierra Club stated that the benefits of listing SCMs were 

underestimated, since health and welfare should be protected at all cost. 

However, no documentation of this assertion was provided. 

RESPONSE: It is not possible to provide a technical response to such a 

broad assertion. It is felt that all quantifiable benefits have been 

considered. However, it is recognized that all benefits of the regulation are 

presently unquantifiable (e.g. existence value benefits). 

COMMENT: Some comments claimed that the difficulties in quantifying some 

benefit types meant that some benefits were omitted and that overall benefits 

may be underestimated. 

RESPONSE: It is true that some benefit categories had to be omitted due 

to difficulties in measurement or quantification. One example is soiling of 

non-residential buildings. 

COMMENT: Some commenters argued that the RIA based its benefit 

estimates on willingness-to-pay methodology which implicitly sacrifices 

the lives of the generally poor inhabitants around SCMs in order to save 

money on the electric bills of distant consumers. 

RESPONSE: The benefits of reduced mortality risk and morbidity risk for 

SCM populations are included in the RIA. The RIA used a value for mortality 

risk that is applicable nationwide. There was no adjustment for the lower 

incomes of SCM populations. On the other hand, morbidity risk that takes the 

form of lost work days or reduced activity days was valued taking into account 

local wage rates. 

3-16 
P.30 

I 

fl 

i • 

L' 

fl 

SECTION 4.0 

COMMENTS AND RESPONSES ON INTERPRETATIONS AND PROCEDURES 

FOR DETERMINING AIR QUALITY IMPACT 

4.1 DEFINITION OF SIGNIFICANT IMPACT 

COMMENT: A number of commenters wished to know the basis for defining a 

3 

significant air quality impact to be 1 ug/m (MARC 1986). 

RESPONSE: Table A-3 of "Ambient Monitoring Guidelines for Prevention of 

Significant Deterioration" (EPA 1981a) defines a significant air quality 

3 3 

impact for TSP to be 1 ug/m on an annual basis and 5 ug/m on a 24-hour 

3 

basis. For Class 1 areas the 24-hour value is defined to be 1 ug/m . 

3 

Although this reference was the only one found for the 1 ug/m value, Congress 

has used the value as part of the PSD rules. 

4.2 SPACING OF RECEPTORS 

COMMENT: One comment noted apparent problems with the spacing of 

receptors for the dispersion analyses in the RIA. The interpretation of a 

March 1985 report (PEI 1985) was that receptors were only placed on a regular 

grid pattern and that no receptors were placed around the mine property. 

Therefore, the maximum off-site impact was not adequately defined (TRC 1986). 

RESPONSE: The comment shows that the reader may not have understood the 

paragraph which was referenced. In fact, receptors were placed around the 

mine property as stated in the report. "Model grid receptors used in the ISC 

simulations were placed in a Cartesian coordinate system, spaced at intervals 

of 2.0 to 4.0 kilometers over a range of 28-48 kilometers in both the N-S and 

E-W directions. The receptor density was highest near the coal lease and 

lowest at the edges of the modeled area. Additional receptors were located 

off-site around the perimeter of the leases to assist in defining the off-site 

impact of the mines." (PEI 1985) (Emphasis Added). 

4-1 
P.31 

IS 

m 

fl 

4.3 AIR QUALITY IMPACT OF COAL MINES 

COMMENT: Several commenters referred to a study which suggested that in 

areas where SCM's have displaced agricultural activities, overall particulate 

concentrations were reduced. The basis for this statement was the data 

presented in Table 2. 

RESPONSE: It is difficult to evaluate the data contained in Table 2 

since much additional information is needed. Specifically, the required data 

include: monitor location, source locations, meteorological patterns, 

localized activities, number of samples, precipitation distribution over each 

year (i.e. all at once or spread out over year), surrounding terrain, 

historical data variability, etc. It is true that changes in surrounding land 

use can affect measured concentrations, but it is unlikely that an 

intermittent source such as agriculture can produce higher particulate 

concentrations on an annual basis than 24 hour/day mining activities, at least 

when smaller geographic areas are considered. 

For every value in Table 2 that potentially shows an air quality benefit 

to surface mining over agriculture, other examples show the opposite. For 

example at Cordero site 2 the measured air quality increased from 39 to 69 

ug/m from 1982 to 1983 when mine production went from 7,7 to 10 MMTPY. At 

this time, there is no reason to suppose any air quality benefits for coal 

mines when they replace agricultural activities. 

4-2 
P.32 

3x3 

TABLE 2. Particulate Concentrations Annual Geometric Means (ug/m ) 

iii i 

D 

Monitoring Sites 

Belle Ayr #2 

#5 

#4 

#6 

Caballo C-5 

C-6 

Cordero 1 

2 

3 

Texas Energy 1 

3 

Mobile 

Caballo Rojo 1 

2 

3 

4 

Coal Creek N 

S 

Precipitation (in) 

Belle Fourche 

Drainage 

Gillette 2E 

Departure Norm = DN 

Coal Production 

(MMTPY) 

Belle Ayr 

Caballo 

Cordero 

Texas Energy 

Caballo Rojo 

Coal Creek 

TOTAL 

1980 

38 

46 

45 

27 

26 

22 

33 

52 

28 

15 

19 

—d 

-_ 

--

--

15 

17 

1980 

15.19 

14.77 

1980 

16.0 

2.0 

6.5 

— 

--

24.5 

1981 

36 

47 

53 

32 

27 

23 

35 

44 

30 

17 

21b 

34 

27 

28 

27 

19 

19 

DN 1981 

-1.10 15 

-1.01 13 

1981 

15.0 

3.8 

8.3 

— 

— 

27.1 

.32 

45 

1982 

21 

25 

39 

23 

17 

19 

37 

39 

29 

15 

23b 

21 

18 

20 

19 

11 

17 

DN 

-0.97 

-2.33 

1982 

15.2 

5.5 

7.7 

--

— 

1.0 

29.4 

1983 

27 

26 

26 

21 

19 

21 

27 

69 

23 

20c 

30c 

21 

20 

25 

21 

15 

14 

1982 

25.41 

26.37 

1982 

13. 

6. 

10. 

--

1 

1 

33 

DN 

+ 9. 

+10. 

8 

7 

0 

4 

9 

8 

% 

12 

59 

Change 

-29 

-43 

-42 

-22 

-27 

- 5 

-18 

+32 

-18 

+33 

+58 

-38 

-48 

-11 

-22 

0 

-18 

1983 DN 

14.25 -2.08 

12.75 -3.10 

% Change 

-14 

+235 

+54 

.--

— 

+90 

+38 

a = Data obtained from Wyoming Air Quality Division records, 

b = Nearby land use change by rancher from native rangeland to row crop, 

c = 2,800 additional acres of native rangeland converted to row crops, 

d = No data. 

e = Climatological Data Annual Summary (1980,1981,1982,1983) National Oceanic and 

Atmospheric Administration. 

4-3 
P.33 

fl 

I 

SECTION 5.0 

RESPONSE SUMMARY AND INTERPRETATION 

5.1 SUMMARY 

Nearly all comments received from the coal industry, and State and 

Federal agencies favored Alternative I which would not list SCMs for PSD 

purposes. These organizations agreed with the RIA's conclusions concerning 

Alternatives II and III; however, they felt that the RIA underestimated costs 

and overestimated benefits. These comments stated that based on the available 

information there is no justification for listing SCMs. Further, they stated 

that if coal mines were listed it would cause economic disruption to the 

industry. 

On the other hand, a few groups argued that SCMs must be listed, since 

health and welfare should be protected at all costs and benefits are more 

difficult to quantify than costs. Also, they believed that additional 

controls are possible to reduce emissions from the mines and allow the mines 

to meet the PSD increments. 

5.2 INTERPRETATION 

Surface coal mines by their nature are difficult sources to quantify. 

Clear, definitive answers are not readily available for this type of 

analysis. The predictive process for estimating particulate concentrations 

around SCMs has not been validated against measured concentrations for 

specific mines. Further, the methodology for evaluating ambient air quality 

impacts of SCMs has not been standardized. Different emission factors and 

dispersion models have been used by various organizations. Until a 

standardized approach is developed, separate analysts evaluating an identical 

SCM will obtain answers that may differ substantially. Both industry and 

environmental groups have their own points of view and agendas. The RIA on 

the other hand, endeavored to structure reasonable and unbiased analyses that 

reflect most likely impacts (and ranges of impacts) given limited information 

5-1 
P.34 

and resource constraints. Because of the uncertainties involved in these types 

of analyses, it is understandable how results would differ across such groups 

given the divergence in points of view. 

In addition to tl,2 alternate methodologies presently employed, there are 

several types of inherent errors in the analyses. Sources of these errors 

include emission factors, activity parameters, source location, meteorological 

data, and the dispersion models. 

Overall, the comments indicate that Alternatives II and III are generally 

not considered to be cost effective. Alternative IV may make it difficult for 

mines to meet the PSD increments near Class I and mandatory Class II areas. 

Finally, the RIA did not consider Indian Reservations in its analyses. 

These Class II areas can be reclassified as Class I areas. If these areas 

would be included in the proposed listing, then the estimates for affected 

coal reserves in the RIA are significantly low. 

5-2 
P.35 

fl 

>»! 

G 

REFERENCES 

American Conference of Governmental Industrial Hygienists (ACGIH), 1988. 

Threshold Limit Values and Biological Exposure Indicies for 1988-1989, 

Cincinnati, Ohio. 

Cummings, R.G., D.S. Brookshire, and W.D. Shulze, ed., 1986, Valuing 

Environmental Goods: A State of the Arts Assessment of the Contingent 

Valuation Method. Rowan and Allanheld, Totawa, NJ. 

Dineh Service Company, 1986. Comments to Docket No. A-84-33. 

Evans and Cooper, 1980. An Inventory of Particulate Emissions from Open 

Sources. JAPCA, Vol. 30, No. 12. 

MacFarland, K., W. Malm, and J. Molenar, 1983. An Examination of 

Methodologies and Social Indicators for Assessing the Value of Visibility, in 

Rowe and Chestnut (eds.), Managing Air Quality and Natural Resources at 

National Parks and Wilderness Areas, Westview Press, Boulder, CO. 

MARC, 1984. Comments from Mining and Reclamation Council (MARC) to Docket No. 

A-82-43. 

MARC, 1986. Testimony of Robert B. Flagg and Ken Williams on Behalf of the 

Mining and Reclamation Council of America at the Environmental Protection 

Agency. 

Mitchell, R.C., and R.T. Carson, 1988. Draft Manuscript. Using Surveys to 

Value Public Goods: The Contingent Valuation Method. Resources for the 

Future, Washington, D.C. 

Montana Coal Council, 1986. Comments to Docket No. A-84-33. 

NCA, 1986. Comments of National Coal Association on EPA's Regulatory Impact 

Analysis of its Proposed Listing of Surface Coal Mines as a Source Category 

for Which Fugitive Emissions Must be Included in PSD Threshold Applicability 

Determinations. Docket No. A-84-33. 

PEI Associates, Inc. 1985. Characterization of TSP Air Quality Around Surface 

Coal Mines Near PSD Class I and Mandatory Class II Areas. Prepared for the 

U.S. Environmental Protection Agency and The National Park Service. Contract 

No. 68-02-3890. 

Rae, D., 1983. The Value to Visitors of Improving Visibility at Mesa Verde and 

Great Smoky National Parks, in Rowe and Chestnut (eds.), Managing Air Quality 

and Natural Resources at National Parks and Wilderness Areas, Westview Press, 

Boulder, CO. 

R-l 
P.36 

fl 

n 

E 

G 

Randall, A., Grunewald, 0., Pagoulatos, A., Ausness, R., and Johnson S. 

(1978). Estimating Environmental Damages for Surface Mining of Coal in 

Appalachia: A Case Study, U.S. Environmental Protection Agency, Industrial 

Environmental Research Laboratory. 

Review of NAAQS for Particulate Matter: Assessment of Scientific and Technical 

Information, Office of A-Q-P-S, Staff Paper, EPA-4501 5-82-001, January 1982. 

Rowe, R.D., R. d'Arge, D. Brookshire, 1980. An Experiment in the Economic 

Value of Visibility, Journal of Environmental Economics and Management 7: 

1-19. 

Schulze, W.D., D. Brookshire, E. Walther, K. Kelley, 1981. Methods Development 

for Environmental Control Benefits Assessment, Vol. VIII, The Benefits of 

Preserving Visibility in National Parklands of the Southwest, prepared for the 

U.S. Environmental Protection Agency, Washington, D.C. 

Sierra Club, 1986. Sierra Club's Second Supplemental Comments on EPA Proposal 

to List Surface Coal Mines as a Major Source of Fugitive Emissions. 

TRC Environmental Consultants, Inc., 1985. Quantification of Uncertainties in 

EPA's Fugitive Emissions and Modeling Methodology at Surface Coal Mines. 

TRC Environmental Consultants, Inc., 1985a. A Performance Evaluation of the 

EPA's ISC Model. 

TRC Environmental Consultants, Inc., 1985b. Modeled Air Quality Impacts of 

Four Hypothetical Surface Coal Mines. 

TRC Environmental Consultants, Inc., 1985c. Modeled Air Quality Impacts of a 

Hypothetical North Dakota Lignite Mine Surface Coal Mine. 

TRC Environmental Consultants, Inc., 1985d. Modeled Air Quality Impacts of a 

Hypothetical Texas Lignite Mine. 

TRC Environmental Consultants, Inc., Letter from Mr. Kirk Winges to Mr. 

Dennis Hunter of Utah International, Inc. 

U.S. Environmental Protection Agency, 1978. Survey of Fugitive Dust from Coal 

Mines. EPA-908/1-78-003. Office of Energy Activities, Denver, Colorado. 

U.S. Environmental Protection Agency, 1981. Improved Emission Factors for 

Fugitive Dust from Western Surface Coal Mining Sources. Prepared by PEDCo 

Environmental Inc. and Midwest Research Institute. 

U.S. Environmental Protection Agency, 1981a. Ambient Monitoring Guidelines 

for Prevention of Significant Deterioration (PSD). EPA-450/4-80-012. 

U.S. Environmental Protection Agency, 1982. Characterization of PM10 and TSP 

Air Quality Around Western Surface Coal Mines. EPA-450/4-83-004. Office of 

Air Quality Planning and Standards Research Triangle Park, N.C. 

R-2 
P.37 

D 

U.S. Environmental Protection Agency, 1985. Regulatory Impact Analysis, 

Listing of Surface Coal mines for New Source Review. 

U.S. Environmental Protection Agency, 1986. Transcript of Proceedings. In the 

Matter of Proposed Regulations to Subject Surface Coal Mines to Prevention of 

Significant Deterioration Review. Federal Office Building, Denver, Colorado, 

April 9, 1986. 

-1 

I R-3 

i