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APPENDIX P <br />McClave Canyon Mine Expansion and Fruita Loadout Facility Biological Assessment <br />produces an, enzyme that detoxifies the PAHs, but then .generates more carcinogenic and <br />mutagenic and carcinogenic by-products -(Campbell and Devlin, 1997). <br />Coal could enter the water in Reed Wash, the 100 -year floodplain, and designated critical <br />habitat for Colorado pikeminnows-as fugitive .dust.from the stockpile' and transfer processes -at <br />the Loadout Facility, ;as fugitive dust from loaded coal cars, -and from released coal from bottom <br />doors of loaded. coal cars crossing Reed Wash, -EPA requires a Fugitive Coal Dust Emission <br />Control Plan (40 CFR ,Chapter I, Section 60.254) that incorporates one or more measures that <br />will limit fugitive coal dust to the greatest extent practicable. Control measures permitted at the <br />Loadout Facility by the CDPHE Air Pollution Control Division (Permit.No. 10ME2000, page 6) <br />include: <br />1. Emissions from material -handling (i.e.­ remdval, ,loading, and hauling) shall be <br />controlled- by use of , partial enclosures and watering at all times unless natural <br />moisture is sufficlent to, control emissions. <br />2. Unpaved.haul roads shall be graveled,=as per initial application, and watered as often <br />as needed to control fugitive particulate emissions such that the above guidelines are <br />met. - . .1 - <br />3. Plant entryway and truck service roads shall be graveled or paved. Watering shall <br />be implemented if emission guidelines above are not met. - ` <br />Wind -related loss of coal at,the Loadout Facility was modeled (Air Resource Specialists, -2010) <br />to include hourly and annual emissions of particulates from various components at -the Loaddut <br />Facility. Without control of fugitive dust, model -results indicate there would be 7.6 tons 'of <br />fugitive PM10 (particulate matter 510 pm) - emitted ..per year by the Loadout Facility. -With <br />emission controlsapplied,- total .fugitive PM1a emissions were estimated' at 4.8 tons per year;;.a <br />reduction of .37 percent .Most -fugitive emissions would be'caused by coal dozing,to maintain <br />the coal- stockpile (4:008 tons/year), coal hauling on haul roads (0.411 tons"/year), and wind - <br />generated fugitive coal dust from the.stockpile (0.368,toris/year) (Air Resource Specialists, <br />2010). Annual deposition of fugitive coal dust in Reed Wash or the 100 -year floodplain was riot <br />estimated, althaUgh it would be minimized by the Fugitive Coal Dust Emission Control Plan. <br />National Coal Transportation Association- ('NOTA,- 2007), reported, results of studies conducted <br />by Burlington-NorthernSanta Fe (BNSFj Railroad along; the Powder Rivet Basin Joint ,.Line. <br />Coal lost -from coal cars_ in transit was measured to determine;efficacy of treatments to reduce <br />coal loss. Bottom loss of coal from rapid discharge car -doors was, on average 19 pounds:per <br />car for a 216 -mile trip. After adjusting rail car doors, there was a 32 percent decrease iri bottom <br />loss.(NCTA, 2007). In addition, dust collectors were -attached to the tops of loaded.coW cars: <br />During a 567 mile test run, -225 pounds of coal per: car were lost from the tops -of uhtreated'coal <br />cars -but only 52 pounds per 'car were lost'from ,coal sprayed with a dust -suppression chemical. <br />Coal could enter Reed - Wash and the 100 -year floodplain either escaping" from bottom doors <br />when loaded coal cars - are on the' 120 -foot long open deck rail bridge 'prop'osed, to span the <br />creek and floodplain and/or from fugitive coal dust in loaded cars on the bridge or in the vicinity. <br />Because -there will be' approximately 50 unit coal trains per year with 100 to'110 coal cars per <br />unit train, -colcuiations with. simplifying.'assumptions (uniform loss of coal per. distance traveled) <br />using the above data yields estimates of 10 to 11 pounds of coal per year entering the 100 -year <br />floodplain from coal car bottom doors (unadjusted) and up to 50 pounds of fugitive coal dust <br />(untreated) per year from car tops. <br />Rail'Bed and Bridge Construction.' Reed Wash and the 100 -year floodplain would,be crossed <br />by .the railroad spur -an a -117-foot lobg: bridge. Construction of the spur would aifeet <br />approAmawy 0.045 acre within the 100 -year floodplain on the west bank of Reed Wash and <br />0.048 acre on the east bank. Fractured hard rock from a nearby quarry would be used to build <br />24 <br />PR -02 10/12 <br />