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AIR QUALITY STUDY PLAN <br />INTRODUCTION <br />Climatological information is required by <br />Rule 2.04.8 of the CDMG regulations which <br />states that "When requested by the Division <br />the application shall contain a statement of <br />the climatological factors that aze <br />representative of the proposed permit area. " <br />This requirement will be fulfilled by <br />meteorological data collected from a weather <br />station near Trinidad. As a result, no onsite <br />monitoring is anticipated. <br />Even though the Lorencito Project will <br />primarily be an underground mining <br />operation, there will still be surface <br />operations and activities. These surface <br />operations, as well as the mine ventilation <br />exhaust, will result in the release of <br />particulate into the atmosphere. As part of <br />the permitting process it is necessary to <br />determine the ultimate effect of these <br />particulate on the local air quality. <br />In addition to the climatological section <br />of the CDMG permit application, we would <br />prepare a permit application for submittal to <br />the Colorado Air Pollution Control Division <br />(CAPCD). Briefly, the permit application <br />would contain the following: <br />• process description to include site <br />drawings, <br />• expected hours of operation, e.g., <br />continuously 365 days per yeaz, six days <br />per week, 20 hours per day, <br />be PM,o in coal dust from a breaker, <br />nitrogen oxides, or carbon monoxide <br />from generators or heating units. <br />Emission would be estimated from the <br />US EPA document AP-42, Compilation <br />of Air Pollutant Emission Factors, <br />Volume I: Stationary Point and Area <br />Sources, or manufacturer's specification, <br />• estimation of fugitive dust (PM,o) <br />emissions from extracting, conveying, <br />stockpiling, and transporting raw coal; <br />transporting waste coal to and deposition <br />at dump site; loading, conveying, and <br />transporting crushed coal oft-site; and <br />fugitive dust emissions from disturbed <br />land and haul roads. These emissions <br />would also be estimated using AP-42. <br />The time required to complete the permit <br />application would be 30 days. Upon <br />acceptance of the permit application by the <br />CAPCD, the permit approval process would <br />take a minimum of 135 days. However, the <br />process may take longer if permit backlogs <br />exist in the department at the time of <br />submittal. This permit application would be <br />submitted about the same time as the CDMG <br />permit application. <br />The process to permit a diesel-fueled <br />generator to provide power for the site will <br />depend on the size of the .generator. <br />According to the Environmental Protection <br />Agency document AP-42, Compilation of <br />Air Pollutant Emission Factors, Volume I: <br />Stationary Point Sources, potential emissions <br />from adiesel-fueled generator would be as <br />follows: <br />• estimation of emissions from stationary <br />point sources. Potential pollutants would <br />14 <br />