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2013-04-11_REVISION - C1981018
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2013-04-11_REVISION - C1981018
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Entry Properties
Last modified
8/24/2016 5:19:27 PM
Creation date
4/11/2013 12:57:25 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981018
IBM Index Class Name
Revision
Doc Date
4/11/2013
Doc Name
Letter to SHPO (Emailed) & Attachment
From
DRMS
To
SHPO
Type & Sequence
PR8
Email Name
ZTT
DIH
Media Type
D
Archive
No
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With respect to potential ozone formation, the county level analysis of the emissions inventory <br />suggests the region is potentially NOx limited (background biogenic VOC emissions not shown <br />in EPA NEI). Therefore, to effectively limit any potential for ozone formation due to area <br />emissions, control methods should focus on reducing NOx emissions. By continuing to limit the <br />minor reaction species, ozone formation potential from area emissions should remain small. The <br />reader should be advised that only full scale photochemical grid modeling (which is beyond the <br />scope of this EA) can reasonably predict the limiting reactant. The BLM provides the above <br />assertion based on reasonably available literature analyzing potential ozone formation in rural <br />areas during the typical ozone season (i.e., summer). The Deserado Mine sources (including all <br />of the diesel fired mobile sources) and associated processing equipment are not significant <br />sources of NOx or VOC emissions (see earlier discussion on CMM VOC data limitations), the <br />photochemical reactivity potential of methane in the troposphere is considered negligible <br />(40CFR51.100 (s)), and therefore the mine's operations are not expected to contribute <br />significantly to any regional ozone formation potential. <br />The Deserado Mine produces relatively insignificant quantities of PM2.5 emissions as compared <br />to the total Rio Blanco County inventory. The majority of the mine's PM2_5 emissions are from <br />process equipment and fugitive dust sources. These sources are not stack based dispersion <br />sources which generally means that there is only a limited potential for the emissions to become <br />effectively entrained in ambient air with sufficient buoyancy to produce measurable offsite <br />impacts. This is primarily due to the low release height and near surface air turbulence that <br />leaves the particles temporarily close to the ground where they are subject to removal by <br />impaction on nearby horizontal and vertical surfaces, including ground, vegetation, and other <br />structures. For this reason, it is not expected that the mine would have significant impacts <br />regional PM2_5 air quality standards. <br />Potential Impacts Analysis for Greenhouse Gas Pollutants <br />According to the U.S. Global Change Research Program (2009), global warming is unequivocal, <br />and the global warming that has occurred over the past 50 years is primarily human - caused. <br />Standardized protocols designed to measure factors that may contribute to climate change, and to <br />quantify climatic impacts, are presently unavailable. As a consequence, impact assessment of <br />specific impacts related to anthropogenic activities on global climate change cannot be <br />accurately estimated. Moreover, specific levels of significance have not yet been established by <br />regulatory agencies. Therefore, climate change analysis for the purpose of this environmental <br />assessment within this air quality section is limited to accounting for GHG emissions changes <br />that would contribute incrementally to climate change. Qualitative and quantitative evaluations <br />of potential contributing factors are included where appropriate and practicable. <br />The analyzed methane emissions associated with the Deserado Mine are relatively low when <br />compared to other Colorado underground coal mines. Methane emissions estimates are provided <br />in the direct emissions table above. The estimations are based on current emission levels at the <br />Deserado Mine (2009, 2010, & 2011). <br />Approximately 10.5 percent of U.S. emissions of methane come from underground coal mining <br />activities (EPA 2010). Based upon the Inventory of U.S. Greenhouse Gas Emissions and Sinks <br />1990 -2010 (Draft), Februraty, 27, 2012, and the Final Colorado Greenhouse Gas Inventory and <br />DOI- BLM -CO- 110- 2012- 0023 -EA 26 <br />
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