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EFCI's existing air emissions permits do not specify a air quality <br />monitoring program. The primary reasons air quality monitoring is not <br />required include EFCI's limited production levels, lack of significant <br />mining related emissions, absence of significant pollution sources in <br />the immediate area, and local climatic factors. Current Colorado <br />Department of Health-Air Quality Control Division permitting requirements <br />do not mandate air quality monitoring for EFCI's current or proposed <br />mining and related operations. Similarly, the U.S. Environmental <br />Protection Agency does not have air monitoring requirements which are <br />specifically applicable to the Southfield operations. Given that there <br />are no specifically applicable Federal, State or local regulations <br />requiring air monitoring, EFCI does not currently or in the future plan <br />to implement an air quality monitoring program. <br />While EFCI does not currently plan to monitor air quality in conjunction <br />with mining, coal processing, and related operations, specific measures <br />designed to effectively control fugitive dust emissions are an integral <br />part of EFCI's mining, processing, and reclamation plans. <br />Because the Southfield Mine is an underground operation, there are <br />inherent limitations on the extent of surface disturbance. EFCI's surface <br />facilities are limited to a relatively small area which constitutes less <br />than 4% of the total permit area. The majority of EFCI's surface <br />operations are associated with handling and storage of either coal or coal <br />refuse products. There is some degree of fugitive dust control inherent <br />in all of the operations because both coal and refuse products contain a <br />relatively high percentage of surface moisture. <br />Movement of coal from the mine to the raw coal stockpile, coal reclaim <br />from the raw coal stockpile and transfer to the coal preparation plant, <br />and separation of coal and coarse refuse in the rotary breaker, all offer <br />limited potential for fugitive dust emissions since all conveyors are <br />covered, transfer points are enclosed, and the raw coal product contains <br />a significant percentage of surface moisture. <br />n <br />U <br />2.05.6-2 <br />