2008-02-22_APPLICATION CORRESPONDENCE - C2008086 (39)

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CHAPTERFOUR Environmental Consequences and Mitigation No Action Alternative The No Action Alternative would result in air emissions remaining the same as they are today. There would be no increases in fugitive particulates, NOX, SO2 or CO. Proposed Action Alternative Construction and operation of the proposed mine will result in both temporary and ongoing emission increases to the atmosphere. Emissions were divided into three distinct groups, coinciding with the three individual phases of the project: Phase 1 -Railroad Construction; Phase 2 -Mine Area, Transmission Line, and Haul Roads Construction; and Phase 3 - Production (i.e., coal mining operations). Estimated criteria pollutant emissions from the project, grouped by project phase, are shown in Table 4-4, Projected Emission Increases for the Proposed Red Cliff Mine, and detailed emission summaries for each type of emission source/activity are provided at the end of Appendix G. Table 4-4: Projected Emission Increases for the Proposed Red Cliff Mine, (tpy)i Phase 2 Phase 1 Phase 3 Pollutant Construction: Mine ArealTransmission Railroad Construction production Line /Haul Roads NOg~ 73.16 25.16 80.20 COZ 0.05 0.023 0.04 SOx~ 23.97 8.36 24.34 PMio~ 27.71 15.71 9.57 PM2,52 84.10 49.54 24.13 Tons per Year z NOX =Nitrogen Oxides; CO =Carbon Monoxide; SOX =Sulfur Oxides; PMio and PM2.5 = Parkiculate Matter with diameters less than 10 micron and 25 micron, respectively Based on these estimated emission rates, a minor source air quality construction permit will be required in order to begin construction of the mine area. Major source, or PSD, air permitting will not be required. However, due to the amount of estimated emissions associated with the production phase, an air quality modeling analysis for the production phase emissions will likely be required by the Colorado Department of Public Health and Environment (CDPHE) as part of a minor source air quality construction permit application. An air quality operating permit will not be required for the permanent facility. A "near-field" analysis was conducted to assess impacts occurring within 1 km of the proposed mine site using the AMS/EPA Regulatory Model (AERMOD). A "far-field" analysis was conducted using the EPA-approved CALPUFF model to assess impacts to Air Quality Related Values (AQRVs) in Class I and sensitive Class II areas within 200 km of the proposed mine area site. A brief description of both models and the various model inputs are provided in the Appendix G air quality modeling report. Short term (1-hr, 3-hr, 8-hr, 24-hr) and long-term (annual) impacts were assessed for several Clean Air Act "criteria" pollutants in both the near- field and far-field analyses. Additionally, potential visibility impacts, nitrogen deposition amounts, and sulfur deposition amounts were assessed in the far-field analysis, in accordance 4-59 DBMS 614