2020-10-27_PERMIT FILE - C1981035 ‎(22)‎

• Permit No: C1981035
• IBM Index Class Name: Permit File
• Doc Date: 10/27/2020
• Section_Exhibit Name: KII Appendix 16 Dunn Ranch LBA Technical Resources Report
• Media Type: D
• Archive: No

the facility's GHG emissions allowed for back calculating the total coal throughput for the facility and the
total clinker produced for the reporting year.The facilities reported 2014 criteria emissions was obtained
from USEPA's inventory database to use as correlation parameters and provide for the upper level of
emissions that the shipped Proposed Action coal would produce from the facility.To estimate the mercury
emissions, the BLM multiplied the 2014 production data (derived from FLIGHT metrics) by the permit
listed performance standard of 55 pounds(Ibs)of mercury per MM-tons of clinker produced.All the 2014
emissions were corrected to account for the variance between the report year, and Proposed Action coal
use levels.
2.2.2.4 Cement Production
The chemical reactions involved in the manufacture of clinker inherently produce or liberate CO2 in the
process. Unfortunately, USEPA's FLIGHT data only provides speciated data for the Tijeras facility. The
Pueblo facility is monitored by CEMS (continuous emissions monitoring system) as a single stream and
would therefore include both the combustion and reaction related emissions. For the purposes of
disclosure, calcification emissions are presented for both facilities relative to the Tijeras facility given that
the chemistry for clinker production is mostly equivalent regardless of where it is produced.The total CO2
emitted from the calcification reaction is estimated to be 697,393 tons based on the relative production
rates that the 181,000 tons of Proposed Action coal shipments (delivered to Pueblo and Tijeras) would
provide in the maximum year.
2.2.2.5 General Combustion
This analysis assumes that the remaining portion of the maximum year coal to be shipped (879,040 tons)
from the King II Mine is eventually combusted. Approximately 5,100 tpy is combusted in two regional
narrow-gauge railroads. The remainder would be combusted in well controlled facilities, but potentially
anywhere in northern Mexico and in the southwestern U.S.As can be clearly seen from the differences in
the two GCC Rio Grande facilities detailed above, different plant configurations, locations, permitting
authorities, age, etc., can have vastly different emissions for a relatively similar quantity of the same fuel.
Given that the agencies have no way of knowing where King II Mine coal would be combusted from year-
to-year, or in what quantities (except for coal delivered directly to GCC owned cement plants in Tijeras,
and Pueblo)we are not providing any other criteria or HAP emissions estimates from specific locations in
the southwestern U.S.
Additionally, there currently is not a reliable method for producing emissions inventories of criteria
pollutant from residential coal combustion. The available emissions factors from EPA assume larger
industrial facilities that employ a variety of firing practices and are typically well controlled. It is reasonable
to assume that the rail and residential unit are simple stoker fired and are not controlled. The minor
quantities of coal utilized by these sources is not expected to contribute to localized impacts to air quality,
especially from the rail sources where emissions are spread out along the length of the line (tracks) in
what is assumed to be a linear or uniform fashion. Further these emissions are temporally dispersed,such
that they would not accumulate for a given unit of time in any one area like stationary source emissions
could under certain meteorological conditions. However, coal analysis data was received that allowed for
the estimation of mercury emissions for the Durango Silverton and Chama Narrow Gauge Rail Roads.The
Dunn Ranch Area LBA and Mining Plan Modification 23
Technical Resources Report