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

analysis data shows that the mercury emissions from the anticipated coal combustion would be 0.28 and
0.12 Ibs/yr for each railroad respectively.
However, reasonable estimates of GHG's can be produced from these sources (Table 2.2-16) given that
there are far fewer parameters that affect those emissions compared to the criteria and HAPs.To provide
for these estimates, the GHG emissions factors published by USEPA for use in their GHG reporting
regulations were used(USEPA 2014).Additionally,the estimated calcination CO2 emissions forthe balance
of the coal that is assumed to be combusted in other cement production facilities(approximately 880,940
tpy). For this calculation the derived emissions factor from the Tijeras facility was used (from examination
of EPA's FLIGHT data, metric tons of CO2 per metric tons of clinker produced — 0.33). This was necessary
due to the uncertainty of the fraction of lime contained in other facilities feedstocks, where the amount
of lime directly affects the ratio of CO2 liberated during production. Because the efficiency with which
these other facilities can produce clinker from the amount of coal consumed,the coal to clinker ratio from
the Tijeras facility was used to provide an approximate estimate. Again, this was necessary because the
agencies do not know how much clicker these other facilities,within the USA,produce to allow the derived
emissions factor to be applied directly.
Table 2.2-16 Remaining Coal Combustion King II Mine Emissions (tpy)
Source CO, I CH,, Nz0 COzel
Facility 4,795,915 1 184,259 26,801 17,389,088
1GWPs used from 40 CFR Part 98 Subpart A,Table A-1
2.2.3 Direct Air Quality Effects
The region surrounding the Proposed Action area is currently designated as attainment for all criteria
pollutants. The attainment designation means that no violations of ambient air quality standards have
been documented in the area. Air quality effects are measured by determining whether the area would
continue to be in attainment or not.
A detailed air quality assessment of the mine was conducted by APCD to support permitting of the King II
Mine at currently authorized production rates. According to APCD staff, the mine was not required to
provide any dispersion modeling to support their application since their allowable emissions are so low
(BLM and OSMRE 2017). As the Proposed Action is an effectively a continuation of the 2017 mining, the
modeling that was performed for that project is still applicable here.
The King II Mine is primarily a source of PM10 emissions. More so than other pollutants, PM10 is a localized
pollutant where concentrations can vary considerably.The proximity of any receptor to the mine and the
area's topography between the mine and receptor would greatly influence the level of air quality impacts
associated with PM1o. Design Feature 1a described in the 2017 Federal Coal Lease Modification and
Federal Mine Permit Revision outlines the measures implemented by GCC to minimize direct PM10
emissions from mine facilities.
With respect to potential 03 formation,the mine is not a significant source of precursors (NOx and VOC).
When compared to the NEI, precursor totals for LPC in 2014 shown in Table 2.2-4 above, the mine's
Dunn Ranch Area LBA and Mining Plan Modification 24
Technical Resources Report