MEMORANDUM

From:		Mary Johnson

To:		Coal Preparation NSPS Docket (EPA-HQ-OAR-2008-0260)

Date: 		September 2009

Subject:	Technical Support Document for Particulate Matter and Opacity
Standards for Coal-Handling Equipment – Revised

Introduction

In the April 28, 2008, proposal (73 FR 22901), we concluded that a
fabric filter (baghouse) was the best demonstrated technology (BDT) for
controlling particulate matter (PM) emissions from coal-handling
equipment processing subbituminous and lignite coals.  That
determination provided the basis for the proposed PM and opacity
standards, and also for our proposal requiring that coal-handling
equipment processing subbituminous and lignite coals be vented (i.e.,
connected to a duct or stack) such that a PM performance test could be
conducted on the contained exhaust gas stream.  Multiple commenters
disagreed with our BDT determination for several reasons.  First, they
noted that the use of baghouses to collect subbituminous coal dust
presents potential safety concerns, citing numerous injuries and deaths
that have occurred from explosions and fires at facilities using such
controls.  For this reason alone, the commenters argued that EPA should
not use a baghouse as the basis for the emissions rate.  Second, their
comments noted that although the use of baghouses frequently results in
low stack grain loadings, the practice of returning the collected dust
to the conveyor belt may cause potential problems with fine coal dust
emissions later in the coal handling process, decreasing their overall
effectiveness.  Finally, commenters identified multiple State best
available control technology (BACT) determinations that allow sources to
remove existing baghouses and replace them with passive enclosure
containment systems (PECS), fogging systems, or wet extraction
scrubbers.  Neither PECS nor fogging systems can be vented, so the
requirement to conduct a PM performance test conflicts with such State
BACT determinations.

Based on our review of public comments and subsequent analysis, we
concluded that a baghouse is not the only technology that is BDT for
coal-handling equipment used on subbituminous and lignite coals. 
Depending on the plant-specific circumstances, all four of these
technologies – fabric filters, PECS, fogging systems, and wet
extraction scrubbers – can control PM emissions equally well.  They
all provide equivalent levels of emissions reductions; in addition,
fogging systems, PECS, and the wet extraction systems often have lower
costs than baghouses.  For this reason, and as explained further below,
we no longer considered requiring that all emissions from such
facilities be vented and proposed in the May 2009 supplemental proposal
PM and opacity limits for coal-handling operating based on the level of
reduction achievable by these four technologies.

In the April 2008 proposal, we also determined that the use of chemical
suppressants was BDT for coal-handling equipment processing bituminous
coal.  This determination also provided a basis for the proposed PM and
opacity limits.  Multiple commenters disagreed with that determination,
stating that wet suppression is often used to control fugitive PM from
coal-handling operations processing bituminous coal and that this
control approach results in limited visible emissions from the
operation.

Based on our review of public comments and subsequent analysis, we
reaffirmed our determination that BDT for coal-handling equipment
processing bituminous coal is the use of chemical suppressants.  The
proposed opacity limit is based on that BDT determination.  However, it
is important to note that although our BDT analysis identifies a
specific technology as BDT, the actual requirement in the rule is an
opacity limit, and an owner/operator can use any combination of controls
at a particular site as long as it demonstrates compliance with the
opacity limit.  The owner/operator is not obligated to use the specific
technology identified as BDT.

Since the original proposal, we have performed an extensive
data-gathering effort for both PM performance test data and opacity
observations (both Method 9 and Method 22) on recently installed
coal-handling equipment.  We used both the 2005 and 2008 preparation
plant surveys published in Coal Age magazine in combination with the
Department of Energy mine survey to identify new coal preparation
plants.  We also reviewed recent coal boiler installations to determine
if new coal-handling equipment was installed as part of the projects. 
After identifying candidate plants, we contacted the appropriate State
environmental agencies in an effort to obtain copies of both the permit
requirements and performance test data.  States varied significantly in
the resources available to respond to our requests.  In addition, most
State requirements are based on the use of Method 22 observations to
detect the presence of visible emissions, and actual Method 9
performance test data are not required on a regular basis.  In most
cases, if visible emissions are detected, the owner/operator is required
to fix the control equipment and/or adjust operations to eliminate the
visible emissions.  Finally, many of the new coal boilers identified
were located at facilities that already had other coal boilers and were
able to use the existing coal-handling equipment.

Affected Facilities

Open storage piles and coal dust associated with roadways are
potentially significant sources of fugitive PM emissions.  These sources
are integral parts of coal preparation plants, located on contiguous or
adjacent property, and under common control.  As such, they are
contained within the coal preparation (subpart Y) source category;
however, they are not presently listed as affected facilities and are
not presently regulated.  In the April 2008 proposal, we requested
comment on including requirements for open storage piles.  We received
comments both in support of and opposed to including requirements for
open storage piles.  In addition, we received comments in support of
including requirements for the coal dust disturbed by, or released from,
vehicle tires as vehicles move within the coal preparation plant.  Based
on our review of public comments and subsequent analysis, we concluded
that both open storage piles and vehicle tires were significant sources
of potential fugitive PM emissions; however, neither operation lends
itself to an emissions standard.  Therefore, in the May 2009
supplemental proposal, we proposed to establish work practice standards
instead of an opacity or PM limit for these types of affected
facilities.

Clean Air Act section 111(h) provides that if, in the judgment of the
Administrator, it is not feasible to prescribe or enforce a standard of
performance, EPA may among other things, promulgate work practice,
design, or equipment standards.  A determination that the emissions from
the sources cannot be measured due to technological or economic
limitations may be used to support a determination that it is not
feasible to establish standards of performance.  It is difficult and
prohibitively expensive to measure actual PM emissions from individual
open storage piles or roadways.  Further, the size of open storage piles
and the mobile nature of coal dust from vehicle tires on roadways make
the use of Method 9 opacity observations unreasonable in many
situations.  For these reasons, in the May 2009 supplemental proposal,
we proposed to determine that it is not feasible to establish an
emissions standard for open storage piles or the coal dust associated
with roadways.  This determination would support the proposed work
practice standards outlined below.

Based on this proposed determination, in the May 2009 supplemental
proposal we proposed to establish the following work practice standards
for open storage piles and coal dust from roadways.  We proposed to
require owners/operators of open storage piles and roadways associated
with coal preparation plants to develop and comply with a fugitive dust
emissions plan to control fugitive PM emissions.  These fugitive dust
plans must contain the following elements:

1.  For open storage piles, we proposed to require the fugitive dust
plan to prescribe the use of a partial enclosure, chemical suppressants
(including encrusting agents), wet suppression, a wind barrier, or a
vegetative cover to control emissions.

2.  All types of “coal processing and conveying equipment” at a coal
preparation plant are part of the source belonging to the source
category for coal preparation plants.  However, because open storage
piles were not previously affected facilities, unloading and conveying
operations to an open storage pile were not considered “coal
processing and conveying equipment.”  Only unloading operations that
were directly loaded into receiving equipment are considered “coal
processing and conveying equipment” and subject to an opacity limit. 
Because we proposed to include open storage piles as an affected
facility, the loading, unloading, and conveying operations of open
storage piles would also be covered under the fugitive dust emissions
control plan, but not subject to an opacity limit.

Open storage piles also include piles of coal that have been loaded into
trucks, railcars, and/or ships.  In the May 2009 supplemental proposal,
we did not propose to require that the fugitive dust emissions control
plan address emissions from these piles.  We identified two potential
control options for these piles:  covers and chemical encrusting agents.
 However, we have determined it is not practical to require these
controls.  First, the majority of fugitive emissions occur while the
coal is in transit outside the physical boundaries of the coal
preparation plant.  The emissions from the piles while they are at the
coal preparation plant have not been shown to be significant.  Second,
it would not be economically feasible to require end users to cover the
coal or spray chemical suppressants as the coal arrived on the property
of the owner/operator and then proceed to unload the coal.  EPA is not
addressing emissions from these piles at this time.

For roadways, we proposed to require that the fugitive dust plan require
the owner/operator to pave the roads, wet the road surface, sweep up
excess coal dust, or install tire washes to remove entrained dust to
control PM emissions.

Comments provided on the May 2009 supplemental proposal pointed out that
the Surface Mining Control and Reclamation Act (SMCRA) covers fugitive
dust emissions from roads at coal preparation and processing plants at
mine sites and requires a fugitive dust plan.  EPA believes that coal
moving operations, once the coal enters the “coal preparation
plant,” will be by conveyor rather than by truck.  Therefore, we
believe that the requirements of SMCRA are sufficient to address air
emissions from roadways that may be found within a coal preparation and
processing plant at mine sites.  For coal preparation and processing
plants at end-user facilities, we believe that, again, once the coal
enters the “coal preparation plant,” coal moving operations will be
by conveyor rather than by truck.  Thus, EPA has decided not to finalize
the proposed requirements for roadways.  In the May 2009 supplemental
proposal, EPA proposed to require that the fugitive coal dust emissions
control plan include procedures for limiting emissions from all types of
“coal processing and conveying equipment” at a coal preparation and
processing plant.  EPA agrees with commenters that subpart Y should
specifically designate each type of affected facility subject to the
fugitive dust emissions control plan and, therefore, we are not
finalizing that proposed requirement.

A fugitive coal dust emissions control plan is required for open storage
piles, which include the equipment used in the loading, unloading, and
conveying operations of the affected facility, constructed,
reconstructed or modified after May 27, 2009.  The owner or operator is
required to prepare and operate in accordance with a submitted fugitive
coal dust emissions control plan that is appropriate for the site
conditions.  The fugitive coal dust emissions control plan must identify
and describe the control measures the owner/operator will use to
minimize fugitive coal dust emissions from each open storage pile.  For
open coal storage piles, the fugitive coal dust emissions plan must
require that one or more of the following control measures will be used
to minimize to the greatest extent practicable fugitive coal dust: 
locating the source inside a partial enclosure, installing and operating
a water spray or fogging system, applying appropriate chemical dust
suppression agents on the source (when additional provisions discussed
below are met), use of a wind barrier, compaction, or use of a
vegetative cover.  The owner or operator must select, from the list
provided, the control measures that are most appropriate for the site
conditions.  Where appropriate chemical dust suppression agents are
selected by the owner/operator as a control measure to minimize fugitive
coal dust emissions, only chemical dust suppressants with Occupational
Safety and Health Administration (OSHA)-compliant material safety data
sheets (MSDS) are allowed, the MSDS must be included in the fugitive
coal dust emissions control plan, and the owner/operator must consider
and document in the fugitive coal dust emissions control plan the
site-specific impacts associated with the use of such chemical dust
suppressants (e.g., water run-off, water quality concerns).  An
owner/operator may petition the Administrator requesting approval of a
control measure other than those specified above.

Opacity Standard

In the April 2008 proposal, we proposed to amend the opacity limit for
coal-handling equipment from the existing limit of less than 20 percent
to less than 5 percent.  Multiple commenters opposed that proposal for
several reasons.  First, the data used for the proposal were largely
based on data collected from the nonmetallic minerals processing
industry.  In addition, commenters noted that because individual Method
9 opacity observations are made in increments of 5 percent, a less than
5 percent opacity limit would mean that the presence of any visible
emissions would result in a violation.  Commenters asserted that it
would be difficult to guarantee that each affected facility will operate
with no visible emissions at all times.  Also, because the proposed
standard is based on a 6-minute reading, there would be no opportunity
for an owner/operator to fix a problem prior to being in violation of
the standard.  Further, because opacity from fugitive sources is more
difficult to measure than from point sources, they argued that the less
than 5 percent limit was unreasonable.

It is important to note that the April 2008 proposed limit of less than
5 percent opacity is not the same as a no visible emissions limit.  A
Method 9 performance test is one or more sets of 24 observations taken
at 15-second intervals over a 6-minute period.  Because each observation
is reported in 5 percent increments, a 6-minute average can includes
both 0 and 5 percent opacity readings (or higher), as long as the
average is less than 5 percent.  In contrast, a “no visible
emissions” limit for a Method 9 performance test would require all
opacity readings to be 0 percent.

Nonetheless, based on our review of public comments and subsequent
analysis, in the May 2009 supplemental proposal, we proposed to change
the opacity limit for all subpart Y coal-handling facilities to 5
percent.  We gathered data on coal-handling operations at 25 coal
preparation plants and the reported highest 6-minute average opacity
reading was 5 percent for a recently installed facility.  Therefore, we
concluded that this was an appropriate opacity limit for new sources.

We also specifically requested comment on whether an opacity limit of
less than 10 percent is more appropriate than a limit of 5 percent.  The
data we collected were primarily from initial compliance tests, and we
requested comment on whether the 5 percent limit is achievable on a
long-term basis for all subpart Y coal-handling facilities under all
operating conditions, including windy dry periods, and whether the limit
provides an adequate compliance margin.  We also considered establishing
different opacity limits for each coal-handling operation.

Based on comments received and a review of the data, for the final rule
we are establishing an opacity limit for these sources of less than 10
percent.

Numerous comments were submitted to EPA regarding the opacity testing
and monitoring requirements included in the May 2009 supplemental
proposal.  Commenters objected to the proposed procedures as being
unreasonable, burdensome, too complex, and confusing.  Based on our
review of public comments and further analysis, we modified the proposed
requirements where we determined the burden could be reduced without
compromising the integrity of the overall testing and monitoring
requirements.  We also attempted to make the requirements in the final
rule less complex than those included in the supplemental proposal.  All
affected facilities subject to emissions limits are required to conduct
initial emissions testing to show compliance with the opacity limits
included in the final rule.  The final rule allows the use of a
continuous opacity monitoring system (COMS) as an alternative to all
other opacity monitoring requirements.  The final rule includes a
60-minute observation period for Method 9 performance testing.  The
observation period may be decreased from 60 minutes to 30 minutes if,
during the initial 30 minutes of the observation of a Method 9
performance test, all the 6-minute averages are less than or equal to
half the applicable opacity limit.  In the final rule, the frequency of
subsequent visible emissions testing is based on the 6-minute average
opacity readings from the most recent performance test. 
Owners/operators of affected facilities where any 6-minute average
opacity reading in the most recent Method 9 performance test exceeds
half the applicable opacity limit are required to conduct a Method 9
performance test within 90 days of the previous performance test. 
Owners/operators of affected facilities where all 6-minute average
opacity readings in the most recent Method 9 performance test are equal
to or less than half the applicable opacity limit are required to
conduct a Method 9 performance test within 12 months of the previous
performance test.  Further, if an opacity performance test is conducted
concurrently with (or within a 60-minute period of) a PM performance
test for affected sources with wet scrubbers that continuously monitor
specified scrubber parameters, no subsequent opacity performance testing
is required.  The final rule allows simultaneous opacity performance
testing for up to three emissions points as long as all three emissions
points are within a 70-degree viewing sector or angle in front of the
observer such that the proper sun position can be maintained for all
three points.  If an opacity reading for any one of the three emissions
points is within 5 percent opacity from the applicable standard
(excluding readings of zero opacity), the observer must stop taking
readings for the other two points and continue reading just that single
point.

As an alternative to subsequent opacity performance testing, the final
rule allows owners/operators of affected facilities to elect to conduct
monitoring as follows:  (1) monthly visual observations of process and
control equipment must be conducted and, if any deficiencies are
observed, the necessary maintenance must be performed as expeditiously
as possible; and (2) daily walkthrough observations consisting of a
single 15-second observation (i.e., visible emissions or no visible
emissions) of each affected facility must be conducted and, if any
visible emissions are observed, within 24 hours corrective actions must
be conducted and the owner/operator must demonstrate that there are no
visible emissions.  If visible emissions are still observed, an opacity
performance test must be conducted within 45 operating days to show
compliance with the applicable opacity limit.  The final rule requires
that opacity performance testing must be conducted at least once every 5
years for each affected facility complying with this alternative
monitoring option.  Each observer determining the presence of visible
emissions is required to meet the training requirements of Method 22 of
appendix A-7 of 40 CFR Part 60.  The final rule also allows the use of a
digital opacity monitoring system in lieu of subsequent opacity
performance testing

The final rule includes separate opacity testing and monitoring
requirements for coal truck dump operations.  EPA determined that a
different approach for opacity performance testing is warranted due to
the intermittent nature of coal truck dumping.  Coal truck dump
operations are subject to the same opacity limits as other coal handling
operations.  The final rule specifies that compliance with the opacity
limit is determined by averaging all 15-second opacity readings made
during the duration of three separate truck dump events.  A truck dump
event commences when the truck bed begins to elevate and concludes when
the truck bed returns to a horizontal position.  The final rule requires
monthly visual observations of the truck dump equipment and, if any
deficiencies are observed, the necessary maintenance must be conducted
as expeditiously as possible.  Subsequent opacity performance testing
using the three truck dump procedure is required to be conducted every
90 days.

PM Standard

In the April 2008 proposal, we proposed to establish a PM limit of 0.011
grams per dry standard cubic meter (g/dscm) (0.0050 grains per dry
standard cubic foot (gr/dscf)) for coal-handling equipment processing
subbituminous and lignite coals.  We also proposed to require that all
such equipment vent emissions such that mass PM emissions from the
facility could be measured.  Multiple commenters disagreed with the PM
limit, saying that it is technically difficult to achieve at some
locations and is more stringent than the BACT determinations from
multiple State permitting authorities.  In addition, commenters
suggested we collect more PM emissions data specific to coal handling
operations.

As described earlier, we have reconsidered our prior BDT determination
and are now proposing to determine that four technologies – fabric
filters, PECS, fogging systems, and wet extraction scrubbers – may be
BDT, and we are establishing PM and opacity limits consistent with that
determination.  Only the fabric filter and wet extraction scrubber
technologies are typically vented to a stack.  PECS and fogging systems
technologies rely on reduced air flow and as such could not be used if
emissions are vented.  Both PECS and fogging systems are designed around
the concept of lower air velocities and sufficient residence time to
allow the suspended coal dust to agglomerate and fall out of the air. 
Requiring venting of either PECS or fogging systems would conflict with
the design criteria of both approaches.  In the May 2009 supplemental
proposal, we proposed to establish both PM and opacity limits that would
apply to all emissions that are mechanically vented, and an opacity
limit that would apply to all emissions that are not mechanically
vented.  EPA assessed the PM emission reductions, costs, and non-air
environment, secondary air, and energy impacts for six model
coal-handling facilities.  The assessment is based on a conservative
cost assumption that coal preparation and processing plant
owners/operators will choose to use enclosures vented to fabric filters
for all affected facilities subject to subpart Y at their plants.  Many
affected owners/operators are expected to choose to comply with the rule
using lower cost alternative BDT controls such as fogging systems,
chemical wet suppression systems, or passive enclosure containment
systems (PECS).  See Coal Preparation Plant Cost & Impact Analysis in
Docket EPA-HQ-OAR-2008-0260 for calculation details.

Based on our review of public comments and subsequent analysis, we
proposed to change the proposed PM limit from 0.11 g/dscm (0.0050
gr/dscf) to 0.023 g/dscm (0.010 gr/dscf).  The PM performance test data
specific to coal-handling equipment ranged from 0.001 gr/dscf to 0.011
gr/dscf.  Based on the performance test data, we have concluded that
although 0.011 g/dscm (0.0050 gr/dscf) is achievable at some locations,
it might not be achievable on a long-term basis for all affected
facilities across the country.  However, we have concluded that 0.023
g/dscm (0.010 gr/dscf) is achievable for all sizes of affected
facilities and provides an adequate compliance margin to be consistently
achievable on a long-term basis for control technologies that are vented
through a stack.  As shown in docket entries 3 and 35, this standard is
also consistent with the majority of recently issued permits.

In the May 2009 supplemental proposal, we indicated that we would be
considering a PM standard of between 0.020 g/dscm to 0.025 g/dscm
(0.0090 gr/dscf to 0.011 gr/dscf) for the final rule.  All the PM
performance test data collected for this supplemental proposal is equal
to or less than 0.025 g/dscm (0.011 gr/dscf).  However, the source with
the highest PM emissions concentration (the Wisconsin Public Service
Corporation Weston 4 power plant in Wisconsin) has permit requirements
in lb/hr of PM emissions and the design emissions rate of those fabric
filters is unclear.  All of the other PM performance test data,
including the individual tests runs, are below the 0.020 g/dscm (0.0090
gr/dscf) limit.

For the final rule, we are finalizing the 0.023 g/dscm (0.010 gr/dscf)
PM limit as proposed in the May 2009 supplemental proposal.

VOC emissions

Water-based cleaning utilizes the difference in specific gravity to
remove coal from ash and other non-combustible material.  The process
can use either water or a media (or suspension) of water combined with a
heavy mineral, usually magnetite.  A heavy mineral gives the suspension
properties similar to a true heavy liquid, which improves the
performance of the coal-cleaning separation process.  The majority of
coal-cleaning operations in the U.S. use water-based technologies;
however, VOC emissions are minimal with either water-based process.  In
true heavy media separation techniques where organic liquids, slat and
sugar solutions, and other liquids are used, VOC emissions could occur,
depending on the properties of the media.

Surface-based separations must be used to clean smaller particles;
water-based cleaning is impractical in these situations.  Surface-based
cleaning takes advantage of the differences in hydrophobocity between
coal and minerals.  In general, coals are hydrophobic (repelled by water
molecules) and oleophilic (attracted to oil molecules).  Minerals are
hydrophilic (attracted to water molecules) and oleophobic (repelled by
oil molecules).  Froth flotation processes use a frother, typically an
alcohol-based compound, and then bubble air through the system.  Because
they are oleophilic, coals tend to attach to air bubbles or oil droplets
while minerals stay in the water solution or away from the oil.  The
coal-bubble aggregate floats to the surface and the minerals remain in
the water and eventually sink to the bottom of the vessel to exit the
cell through a tailings discharge.  To increase the hydrophobicity of
the coal, oil is added to coat the coal and enhance the coal-bubble
attachment.  In addition, a hydrocarbon solution, such as heptane, could
be used to improve the separation process.

Some VOC emissions would be expected from surface-based coal cleaning
techniques, the use of a true heavy liquid for separation, and other
chemical cleaning approaches.  However, the overwhelming majority of
operations use water-based separation in the U.S.  We did not include
standards for VOC emissions in the May 2009 supplemental proposal
because we do not believe that we have adequate actual emissions data to
support numerical standards.  For this reason, we believe that any VOC
emission limits would need to take the form of work practice standards. 
However, we currently do not believe that we have adequate information
or data to develop work practice standards for VOC emissions from coal
preparation and processing plants.  Two potential control technologies
include a regenerative thermal oxidizer and VOC vapor phase adsorption
equipment.  However, because we do not have any data on the VOC
emissions, we cannot calculate the cost-effectiveness or determine what
level of control would be appropriate.  For all these reasons, we are
not including VOC emission limits in the final rule.

Table 1:  Opacity Observations 

Facility Name	Facility Type	State	Coal Processing or Handling Operation
Air Pollutant Control Equipment	Permit Opacity Limit	Observation  Data
Available for Facility	Year Data Collected	Method 9 Opacity Average
Observed	Method 9 Highest

6-min Avg.

Observed	Method 22 Visible Emissions (VE) Observed

Bowie # 2 Mine	Coal mine	CO	Wash plant bin	None identified	20%	Method 9
1994	0%	0%	 

Willow Lake Mine	Coal mine	IL	Coal breaker	Enclosure	20%	Method 9	2002
0%	0%	 



	Coal screen	Water sprays	20%	Method 9	2002	0%	0%	 



	Coal conveyors	Enclosure with water sprays	20%	Method 9	2002, 2004	0%
0%	 



	Coal/synfuel stacker conveyors	none identified	20%	Method 9	2002, 2004
0 to 3%	<20%	 



	Trucking loading	Water sprays	20%	Method 9	2002	0%	0%	 

Cannelburg

Preparation Plant	Coal Mine	IN	Stoker raw coal hopper	None identified
20%	Method 9	1998	avg. not reported	0%	 



	Dump into stoker plant	None identified	20%	Method 9	1998	avg. not
reported	0%	 



	Hopper outlet	None identified	20%	Method 9	1998	avg. not reported	<1%
 



	Belt dump to second hopper	None identified	20%	Method 9	1998	avg. not
reported	3.0%	 



	Truck loading	None identified	20%	Method 9	1998	avg. not reported	11.2%
 

Farmersburg Mine	Coal mine	IN	Main feed to preparation plant drop on
screen to crusher (A1)	None identified	20%	Method 9	1997	11.0%	15.0%	 



	Main feed to preparation plant drop on screen to crusher (A2)	None
identified	20%	Method 9	1997	14.0%	17.0%	 



	Main feed to preparation plant drop on screen to crusher (A3)	None
identified	20%	Method 9	1997	1.3%	4.0%	 



	Clean coal belt exit from prep plant belt to belt transfer 1 (B1)	None
identified	20%	Method 9	1997	0%	0%	 



	Clean coal belt exit from prep plant belt to belt transfer 2 (B2)	None
identified	20%	Method 9	1997	0%	0%	 

Franciso Mine	Coal mine	IN	Chute exit	None identified	20%	Method 9	1997
<1%	<1%	 



	Belt transfer at top of rail load out	None identified	20%	Method 9	1997
0%	0%	 



	Belt drop onto crusher	None identified	20%	Method 9	1997	0%	0%	 



	Crusher exit	None identified	20%	Method 9	1997	0%	0%	 



	Transfer point to clean coal conveyor	None identified	20%	Method 9	1997
0%	0%	 



	Raw coal crusher (screen drop to crusher)	None identified	20%	Method 9
1998	1.0%	2.0%	 



	Crusher transfer to belt	None identified	20%	Method 9	1998	0%	0%	 



	Belt transfer point	None identified	20%	Method 9	1998	<1%	<1%	 

Lyons Mine	Coal mine	IN	Raw Coal Crusher (screen drop to crusher)	None
identified	20%	Method 9	1998	<1%	2.0%	 



	Crusher transfer to belt	None identified	20%	Method 9	1998	<1%	2.0%	 



	Belt transfer point	None identified	20%	Method 9	1998	4.0%	5.0%	 

Monroe City

Preparation Plant	Coal mine	IN	Raw coal transfer top	None identified	20%
Method 9	1997	0%	0%	 



	Raw coal transfer bottom	None identified	20%	Method 9	1997	0%	0%	 



	Clean coal loadout top	None identified	20%	Method 9	1997	0%	0%	 



	Clean coal loadout bottom	None identified	20%	Method 9	1997	<1%	<1%	 



	Truck Loadout	None identified	20%	Method 9	1998	avg. not reported	<1%
 

Somerville Mine	Coal mine	IN	Drop onto screen to crusher	None identified
20%	Method 9	1998	<1%	<1%	 



	Crusher exit to belt	None identified	20%	Method 9	1998	1.5%	4.0%	 



	Surge Bin	None identified	20%	Method 9	1998	2.5%	5.0%	 



	Exit to Belt	None identified	20%	Method 9	1998	0%	0%	 



	Clean Belt Transfer	None identified	20%	Method 9	1998	0%	0%	 



	Drop Point	None identified	20%	Method 9	1998	0%	0%	 



	Drop onto screen	None identified	20%	Method 9	1998	<1%	<1%	 



	Drop onto Belt	None identified	20%	Method 9	1998	0%	0%	 



	Transfer point	None identified	20%	Method 9	1998	<1%	<1%	 

Century Mine	Coal mine	OH	Coal conveyors towers (F001)	None identified
10%	Method 9	2006	0%	0%	 



	Railcars (F001)	None identified	10%	Method 9	2006	2.9%	3.8%	 



	Coal storage piles (F002)	None identified	No VE's Except for 1 min per
60 min	Method 22	2006, 2008	N.A.	N.A.	Observed

no VE's



	Unpaved roadways  (F003)	None identified	No VE's Except for 3 min per
60 min	Method 22	2006, 2008	N.A.	N.A.	Observed

no VE's



	Coal crushing and cleaning operations (F004)	None identified	20%	Method
9	2006	0%	0%	 

Mettiki Coal Mine	Coal Mine	MD	1500 TPH Double-bay Truck Dump	Enclosure
 	None reported	 	 	 	 



	Rotary Breaker & Screening	Enclosure, water sprays	 	Method 9	2007	<1%
 	 

Logansport Mine	Coal Mine	PA	Main Overland Belt from Mine Face	 	 
Inspection report	2006, 2007, 2008	No or "little" dust emissions were
reported by state inspector from facility sources during site visits in
2006, 2007, and 2007.   No Method 9 or Method 22 tests performed by
inspector.



	Coal Storage Piles	 	 	Inspection report





	Short Radial Stacker to 50 ton Surge Bin	 	 	Inspection report





	Con Weld Vibratory Screen	 	 	Inspection report



Shade Creek Coal Mine	Coal mine	PA	Raw coal handling transfer	 	 
Inspection report	2005, 2006, 2008	No visible emissions were reported by
state inspector from facility sources during site visits in 2005, 2006,
and 2008.  No Method 9 or Method 22 tests performed by inspector.



	Dry screens	 	 	Inspection report





	Product coal handling transfer	 	 	Inspection report





	Raw plant coal breaker	 	 	Inspection report





	Raw plant coal screen	 	 	Inspection report





	Coal refuse are manipulation	 	 	Inspection report





	Product coal storage	 	 	Inspection report





	Coal sizer	 	 	Inspection report



Buchanan Mine	Coal mine	VA	Coal preparation plant operations	 	 
Facility logs	2007	Facility logs for monthly periods in 2006, 2007, and
2008 completed by plant personnel recording visible emissions observed
for a specific list of coal processing and handling operations emission
points.  Observations by plant personnel conducted once per week. No
observations greater than 10% recorded in logs. Majority of 10% readings
were consistently for the same emission point, a truck loading
operation. For other emissions points, recorded observations generally
were less than 5%. with an occasional reading between 5 and 10% for some
emission points.

McElroy Coal Mine	Coal mine	WV	Conveyors Drop Points	Wind covers	20%
Method 9	2003	0%	0%	 



	Conveyor System	Weather covers	20%	Method 9	2003	0%	0%	 

South Hollow Preparation Plant Facility	Coal mine	WV	Stoker Belt	Full
enclosure	20%	Method 9	2004	0%	0%	 



	Stoker Bin	Fixed Chute	20%	Method 9	2004	0%	0%	 



	Load Out Belt	Full enclosure	20%	Method 9	2004	0%	0%	 



	Load Out	Fixed-chute	20%	Method 9	2004	0%	0%	 



	RC Belt	Full enclosure	20%	Method 9	2004	0%	0%	 



	RC Belt	Full enclosure	20%	Method 9	2004	0%	0%	 



	Silo Feed (RC)	Full enclosure	20%	Method 9	2004	0%	0%	 



	Silo Feed (RC)	Full enclosure	20%	Method 9	2004	0%	0%	 



	RC Silo	Full enclosure	20%	Method 9	2004	0%	0%	 



	CC Silo Feed	Full enclosure	20%	Method 9	2004	0%	0%	 



	CC Silo	Full enclosure	20%	Method 9	2004	0%	0%	 



	Dump Bins	Full enclosure	20%	Method 9	2004	0%	0%	 



	Truck Dumps	3-sided roofed enclosure	20%	Method 9	2004	avg. not
reported	1.3%	 

Winifrede Preparation Plant	Coal mine	WV	Bin (TP-03)	Full enclosure with
water spray	20%	Method 9	2001	0%	0%	 



	Unloading (TP-04)	Full enclosure with water spray	20%	Method 9	2001	0%
0%	 



	Bin (TP-06)	Full enclosure with water spray	20%	Method 9	2001	0%	0%	 



	Storage (TP-33)	Full enclosure	20%	Method 9	2001	0%	0%	 



	CC Silo (TP-35)	Full enclosure	20%	Method 9	2001	0%	0%	 



	Belt (TP-36)	Full enclosure	20%	Method 9	2001	0%	0%	 



	Belt (TP-40)	Full enclosure	20%	Method 9	2001	0%	0%	 



	Stoker Loadout (TP-41)	Fixed-height chute	20%	Method 9	2001	0%	0%	 



	RC Silo #2(BS4) (TP-18)	Full enclosure	20%	Method 9	2001	<1%	<1%	 



	Loadout (TP-37)	Telescopic chute	20%	Method 9	2001	<1%	<1%	 



	Belt(BS3) (TP-14)	 	20%	Method 9	2001	0%	0%	 

ABC Coke	Coke Plant	AL	Conveyor Belt Number 25A	 	 	Method 9	2004	0%
0%	 



	Conveyor Belt Number 25B	 	 	Method 9	2004	0%	0%	 



	Conveyor Belt Number 101	 	 	Method 9	2004	0%	0%	 



	Conveyor Belt Number 102	 	 	Method 9	2004	0%	0%	 



	Conveyor Belt Number 103	 	 	Method 9	2004	0%	0%	 



	Conveyor Belt Number 104	 	 	Method 9	2004	0%	0%	 



	Conveyor Belt Number 105	 	 	Method 9	2004	0%	0%	 

Council Bluff Energy Center	Power Plant	IA	East coal silo coal conveying
(ID# 014)	Fabric filter 	40%	Method 9	2007	0%	0%	 



	Coal transfer house #4 (ID #013)	Fabric filter 	No VE's	Method 9	2008
0%	0%	 

Red Hills Generation Facility	Power Plant	MS	Primary crusher and
conveyors (AA-007)	Reverse air fabric filter	20%	Method 9	1998	0%	0%	 



	Secondary crusher and conveyors (AA-008)	Reverse air fabric filter	20%
Method 9	1998	0%	0%	 



	Coal bunker conveyors (AA-010)	Reverse air fabric filter	20%	Method 9
1998	0%	0%	 

Hardin Generating Station	Power Plant	MT	Coal unloading	Fabric filter	 
Inspection report	2008	"No excess visible emissions" were reported by
state inspector from facility sources during site visit in 2008.   No
Method 9 or Method 22 tests performed by inspector.



	Coal silo	Fabric filter	 	Inspection report	2008





Coal storage bunkers	Fabric filter	 	Inspection report	2008

	TS Power Plant	Power Plant	NV	Rail car unloading	Fogging + Enclosure
20%	Method 9	2008	1%	not reported	 



	Coal reclaim operations	Fogging + Enclosure	20%	Method 9	2008	7-9%	not
reported	 



	Coal crusher	Fabric filter	20%	Method 9	2008	0%	not reported	 



	Coal deck tripper	Fabric filter	20%	None reported	 	 	 	 

Seward Station	Power Plant	PA	Coal handling operations	 	 	Inspection
report	2007	No Method 9 or Method 22 test performed by inspector. (rain
reported at site day of inspection)

Santee Cooper Cross Generating Station	Power Plant	SC	Coal bunkers
(P19a-f)	Fabric filter	20%	Method 9	2007	0%	0%	 

Springerville 3	Power Plant	AZ	Coal train unloading (BH1 – BH3)	Fabric
filter	15%	Method 9	2007	0%	0%	 





Fabric filter	15%	Method 9	2007	0%	0%	 





Fabric filter	15%	Method 9	2007	0%	0%	 

Neil Simpson II	Power Plant	WY	Coal silo top	Fabric filter	 	Facility
logs	2008	Daily observation log records for 2008 completed by plant
personnel whether or not visible emissions were observed.  Visible
emissions observed from source on 6 days in 2008 due to control device
bag leaks. Corrective action returned operations to no visible
emissions.



	Coal silo bottom	Passive enclosure containment system (PECS)	 
Facility logs	2008	Daily observation log records for 2008 completed by
plant personnel whether or not visible emissions were observed.  No
visible emissions observed from source in 2008..  



	Boiler building conveyors	Fabric filter	 	Facility logs	2008	Daily
observation log records for 2008 completed by plant personnel whether or
not visible emissions were observed.  No visible emissions observed from
source in 2008..  

DTE Utah Synfuels LLC	Synthetic fuel plant	UT	Coal screens	Water sprays
10%	Inspection report	2006, 2007	No visible emissions were reported by
state inspector from facility sources during site visits in 2006 and
2007.   No Method 9 or Method 22 tests performed by inspector.



	Conveyor transfer points	Water sprays	10%	Inspection report	2006, 2007





Coarse coal crusher	Fabric filter	10%	Inspection report	2006, 2007





Thermal drying ovens (operation discontinued in 2004)	Fabric filter	10%
Inspection report	2006, 2007





Conveyor drop points	None identified	20%	Inspection report	2006, 2007

	

Table 2:  PM Performance Test Data

Company Name 	Facility Name	Facility Type	State	Coal Processing or
Handling Operation	Air Pollutant Control Equipment	Year Data Collected
Method 5 PM Test Average (gr/dscf)

Amax Coal Company	Belle Ayr	Mine	WY	Cooler Stacker	Fabric filter	1990
0.0064

Amax Coal Company	Belle Ayr	Mine	WY	Cooler Stacker	Fabric filter	1991
0.0078

Amax Coal Company	Belle Ayr	Mine	WY	Cooler Stacker	Fabric filter	1991
0.0089

Amax Coal Company	Belle Ayr	Mine	WY	Silo # 1	Fabric filter	1990	0.0034

Amax Coal Company	Belle Ayr	Mine	WY	Screen/Crusher	Fabric filter	1990
0.0052

Amax Coal Company	Belle Ayr	Mine	WY	Blender	Fabric filter	1990	0.0050

Amax Coal Company	Belle Ayr	Mine	WY	Blender	Fabric filter	1991	0.0042

Amax Coal Company	Belle Ayr	Mine	WY	Sample/transfer	Fabric filter	1990
0.0013

Amax Coal Company	Belle Ayr	Mine	WY	Load Out Silo	Fabric filter	1990
0.0061

Amax Coal Company	Belle Ayr	Mine	WY	Load Out Silo	Fabric filter	1991
0.0028

Kaiser Cement Corp.	Permanente Plant	Cement Plant	CA	Coal mill #1	not
identified	1991	0.006





Coal mill #2	not identified	1992	0.005

Haverhill North Coke Co.	Haverhill North Coke Co.	Coke Plant	OH	Coke
screening	Fabric filter	2006	0.0014

Tucson Electric Power Company	Springerville 3	Power Plant	AZ	Coal train
unloading (BH1)	Fabric filter	2007	0.0026





Coal train unloading (BH2	Fabric filter	2007	0.0011





Coal train unloading (BH3	Fabric filter	2007	0.0009

MidAmerica Energy Company	Council Bluffs Energy Center	Power Plant	IA
Rotary car dump (ID#006)	Fabric filter	2004	0.001





East coal silo coal conveying (ID# 014)	Fabric filter 	2007	0.001





Coal transfer house #4 (ID #013)	Fabric filter 	2008	<0.0010

Newmont Nevada Energy	TS Power Plant	Power Plant	NV	Coal crusher	Fabric
filter	2008	0.0007





Coal deck tripper	Fabric filter	2008	0.0010

Wisconsin Public Service Corp.	Weston 4 - North Side	Power Plant	WI
System 1 - New Reclaim Tunnel (P30)	Fabric filter	2008	0.0098





System 2 - New Junction House (P41)	Fabric filter	2008	0.0085





System 3 - New Junction House (P42)	Fabric filter	2008	0.0059





System 4 - Unit Fill Silo System (P43)	Fabric filter	2008	0.0110



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