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McClane Canyon Mine Expansion and Fruita Loadout Facility Biological Assessment <br />produces an enzyme that detoxifies the PAHs, but then generates more carcinogenic and <br />mutagenic and carcinogenic by- products (Campbell and Devlin, 1997). <br />Coal could enter the water in Reed Wash, the 100 -year floodplain, and designated critical <br />habitat for Colorado pikeminnows as fugitive dust from the stockpile and transfer processes at <br />the Loadout Facility, as fugitive dust from loaded coal cars, and from released coal from bottom <br />doors of loaded coal cars crossing Reed Wash. EPA requires a Fugitive Coal Dust Emission <br />Control Plan (40 CFR Chapter I, Section 60.254) that incorporates one or more measures that <br />will limit fugitive coal dust to the greatest extent practicable. Control measures permitted at the <br />Loadout Facility by the CDPHE Air Pollution. Control Division (Permit No. 10ME2000, page 6) <br />include: <br />1. Emissions from material handling (i.e. removal, loading, and hauling) shall be <br />controlled by use of partial enclosures and watering at all times unless natural <br />moisture is sufficient to control emissions. <br />2. Unpaved haul roads shall be graveled, as per initial application, and watered as often <br />as needed to control fugitive particulate emissions such that the above guidelines are <br />met. <br />3. Plant entryway and truck service roads shall be graveled or paved. Watering shall <br />be implemented if emission guidelines above are not met. <br />Wind - related loss of coal at the Loadout Facility was modeled (Air Resource Specialists, 2010) <br />to include hourly and annual emissions of particulates from various components at the Loadout <br />Facility. Without control of fugitive dust, model results indicate there would be 7.6 tons of <br />fugitive PM, (particulate matter <10 pm) emitted per year by the Loadout Facility. With <br />emission controls applied, total fugitive PM, emissions were estimated at 4.8 tons per year, a <br />reduction of 37 percent. Most fugitive emissions would be caused by coal dozing to maintain <br />the coal stockpile (4.008 tons /year), coal hauling on haul roads (0.411 tons /year), and wind - <br />generated fugitive coal dust from the stockpile (0.368 tons /year) (Air Resource Specialists, <br />2010). Annual deposition of fugitive coal dust in Reed Wash or the 100 -year floodplain was not <br />estimated, although it would be minimized by the Fugitive Coal Dust Emission Control Plan. <br />National Coal Transportation Association (NCTA, 2007) reported results of studies conducted <br />by Burlington- Northern Santa Fe (BNSF) Railroad along the Powder River Basin Joint Line. <br />Coal lost from coal cars in transit was measured to determine efficacy of treatments to reduce <br />coal loss. Bottom loss of coal from rapid discharge car doors was, on average 19 pounds per <br />car for a 216 -mile trip. After adjusting rail car doors, there was a 32 percent decrease in bottom <br />loss (NCTA, 2007). In addition, dust collectors were attached to the tops of loaded coal cars. <br />During a 567 mile test run, 225 pounds of coal per car were lost from the tops of untreated coal <br />cars but only 52 pounds per car were lost from coal sprayed with a dust - suppression chemical. <br />Coal could enter Reed Wash and the 100 -year floodplain either escaping from bottom doors <br />when loaded coal cars are on the 120 -foot long open deck rail bridge proposed to span the <br />creek and floodplain and /or from fugitive coal dust in loaded cars on the bridge or in the vicinity. <br />Because there will be approximately 50 unit coal trains per year with 100 to 110 coal cars per <br />unit train, calculations with simplifying assumptions (uniform loss of coal per distance traveled) <br />using the above data yields estimates of 10 to 11 pounds of coal per year entering the 100 -year <br />floodplain from coal car bottom doors (unadjusted) and up to 50 pounds of fugitive coal dust <br />(untreated) per year from car tops. <br />Rail Bed and Bridge Construction. Reed Wash and the 100 -year floodplain would be crossed <br />by the railroad spur on a 117 -foot long bridge. Construction of the spur would affect <br />approximately 0.045 acre within the 100 -year floodplain on the west bank of Reed Wash and <br />0.048 acre on the east bank. Fractured hard rock from a nearby quarry would be used to build <br />24 <br />