2010-12-17_REVISION - C1981019 (108)

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RULE 2 PERMITS Air quality will be protected in accordance with the procedures outlined in the existing permit document. These procedures are currently employed at the existing mining area. Air quality information is included in Exhibit 8 of the existing permit document. The final air pollution control plan is in development pending the collection of new meteorological parameters necessary for modeling. Colowyo maintains fugitive dust control measures as an integral part of all mining and reclamation activities. Presently, Colowyo operates under numerous Emission Permits issued from the Colorado Department of Health, Air Pollution Control Division, as more particularly described in Section 2.03.10. Colowyo conducts air quality monitoring at the site in accordance with the requirements of the emission permits. The principal fugitive dust control practices employed by Colowyo are as follows: Roads Colowyo will employ a dust suppression program for in pit roads and other unpaved roads which primarily involves periodic watering. Mine water trucks will run periodically as needed over the roads wetting down any dusty conditions. During the dryer months of the year, the water trucks will wet down the roads which are being utilized a minimum of two or three times per shift. If determined to be necessary as an addition to periodic watering, a chemical dust suppression agent may be used during the dry months on the primary in pit roads. To this date, however, chemical stabilization of the unpaved in pit roads at the existing operation have not been successful for more than a short period of time due to changing weather conditions and the use of heavy haulage trucks. Colowyo has surfaced "in -pit" roads with gravel or crushed rock; however, no roads in the Collom area pits will be paved with asphalt. Asphalt could not sustain the enormous weights of the haulage equipment currently in use. Likewise, crawler equipment would rip the asphalt surface causing an extremely hazardous condition for all equipment and personnel. All roads in the mining operation will be constantly maintained by a motor grader, scraper, or rubber tired dozer to remove any coal, rock, or any other debris. Smooth and clean road surfaces are essential for not only minimizing dust, but also for allowing efficient, safe and economic use of haulage equipment. The coal haul road from the Collom area primary crusher to the Gossard Loadout is planned to be paved with asphalt to provide for emission control. A strict speed control will be implemented for all roads to control dust and to provide for safe operation of the equipment. Most haul road embankment slopes and adjacent areas will be mechanically stabilized and seeded with a mixture shown in Volume 1, Table 7, Reclamation Seed Mixture. Mechanical stabilization has consisted of furrowing, chiseling, "cat tracking" and mulch, depending on accessibility to the slopes. No travel of unauthorized vehicles will be allowed on anything other than established roads. All overburden haulage equipment will be restricted only to appropriate roads. Colowyo does not plan to cover any of the haul trucks because the roundtrip between the coal crushing facility and the active mining area will be relatively short, and the loaded trucks will be moving slowly. Also, care will be taken by the front -end loader or shovel operators not to overfill any of the haul trucks so as to cause excessive fugitive dust. Coal Crushing Facility Collom — Rule 2, Page 119 Revision Date: 1/23/09 Revision No.: PR -03