Dust Suppression on Wyoming’s Coal Mine Haul Roads

Literature Review

Recommended Practices and Best Available Control Measures – BACM Dust Suppressant Selection Guides

A Manual prepared for: Industries of the Future Converse Area New Development October, 2004 by: Temple Stevenson

Cover photos: courtesy of Triton Coal – Tony Trouchon (photographer)

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TABLE OF CONTENTS

Introduction iii

I. Literature Review: Fugitive Dust and Its Control 1

II. Recommended Practices and Best Available Control Measures 21

Table 2.1 Dust Control Operations Recommendations 25 Figure 2.1 Sample Air Event Outline 26Table 2.2 Best Available Control Measures

BACM (Recommendations) For Controlling Fugitive Dust on Mine Haul Roads 28

III. Dust Suppression � Selection Guides 31 Table 3.1 Dust Suppression Products 33

Table 3.2 Dust Suppression Applications Guide 41Table 3.3 Dust Suppression on Mine Haul Roads

Cost Worksheet (available in excel) 57

Appendices 61

Appendix A: Dust Suppression Survey and Results 63Appendix B: Dust Control Plan and

Self Inspection Checklists 67Appendix C: Palliative Selection Matrix

(Thompson) 73Appendix D: Palliative Selection Matrix

(Bolander and Yamada) 77 Appendix E: Fugitive Dust Bibliography 81

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Introduction

Fugitive dust emissions are increasingly becoming a problem for Wyoming’s surface coal mines located in a windy semi-arid environment where the average wind speed is 13.4 miles per hour and the average rainfall is a mere 14 inches with some of the highest evaporation rates in the nation. Fugitive dust emissions are a nuisance in coal mines; dust impairs visibility, affects the health of employees, increases wear and tear of equipment, and increases road maintenance and costs. Current drought conditions, elevated wind speeds, compliance with air quality and clarity standards impacted by particulate emissions, a predicted increase in coal production, and increased Coal Bed Methane operations has heightened the concern. Dust from surface coal mine operations also has the potential to negatively impact Federal Class I Air Quality Areas in the region, such as Badlands and Wind Cave National Parks and the Northern Cheyenne American Indian Area. While no visibility impairment in these Class I areas is currently attributable to any Wyoming source, it is anticipated that strategies to maintain a status of minimal impact will be of notable value to the Western Regional Air Partnership (WRAP) and the State of Wyoming in the development of its Regional Haze SIP(State Implementation Plan), due by Dec 31, 2008 (Wyoming’s Long Term Strategy for Visibility Protection: Review Report, 2003). It is the intent of this report to contribute to a better understanding of fugitive dust and its mitigation, so that efficient and effective management strategies for suppressing it can be implemented. The report includes four segments: I. Literature Review; II. Recommended Practices and Best Available Control Measures -BACM; III. Dust Control Suppressant Selection Guides; and an Appendices containing a fugitive dust bibliography and document examples.

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I. Literature Review: Fugitive Dust and its Control Sources and Impact of Dust Generated by Surface Coal Mines Haul roads, over-burden piles, drilling and blasting, coal transfers and loading, and topsoil handling are all contributing factors of dust generation in a coal mine. A South African study conducted in an arid climate similar to Wyoming’s by Thompson and Visser (2002) titled “Benchmarking and Management of Fugitive Dust Emissions From Surface Mine Haul Roads,” determined that 93% of the total dust emissions from a coal strip mine could be contributed to coal transport or haul roads. Figure 1. illustrates their findings of the contributions of specific sources of fugitive dust as a percentage of the total fugitive dust generated by a surface coal mine.

93% of the total dust emissions from a coal strip mine could be contributed to coal transport or haul roads

Fig. 1 Percentage contribution to total dust emissions (Thompson & Visser 2002)

Assessing the source and impact of dust to determine the need to increase watering, decrease speed, use dust suppressing chemicals (also known as palliatives), or re-graveling is constricted by a lack of problem solving methodology that takes into account the complexity of various interactions. The interactions include traffic volume, weight, climate, and more according to Thompson & Visser (2002). They add, “most surface mine operators agree that dust-free roads are desirable, but find it difficult to translate this into cost-effective management and mitigation.” This same study found that regular watering and the application of chemical suppressants in conjunction with optimal aggregate surfaces is the only effective option for controlling fugitive dust emissions on haul roads. The most harmful types of fugitive dust to the respiratory system are those that are under 10 microns in diameter, known as PM10’s. Because they are most harmful, they are the

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most monitored. Another common measurement involves total suspended particulates’ or TSP’s. Total suspended particulates refer to the total amount of solid particulates and liquid droplets suspended in the air, regardless of particle size (Ferguson et al., 1999). Wyoming has been monitoring PM10 emissions to meet Federal standards since 1989, before that TSP’s were the only monitored emission. Dust Supp When a coplays a larshould bethe US Fosuccessfualso reducsignificanAt the samaccountedDepartmeManagemview of duparticulararise is of Haul Roa Fugitive dsoils, and generationThe amoususceptibiof haul truunfavorab(Ferguson

Ha19

There havunpaved rForest Sevdust gener

According to EPA officials, exceedences of the 24 hour standard for particulate matter in southern Campbell County escalated substantially over the last 15 years; from 0 incidents during 1990-2000 to 19 incidents from 2001-03.

ression Planning

al mine is in the process of implementing a dust suppression plan, cost analysis ge role in product selection. When looking at a product, an overall cost analysis taken into account. According to Bolander and Yamada (1999) in a report for rest Service entitled “Dust Palliative Selection and Application Guide,” a l dust control program should not only reduce total dust emissions, but it should e maintenance costs. Some dust control products have proven that they can tly reduce overall road maintenance costs and thus achieve an overall savings. e time additional preparation and a change in maintenance practices must be

for. A booklet published by Environment Australia, a branch of Australia’s nt of the Environment and Heritage, Dust Control Best Practice Environment ent in Mining (1998), explains the benefit of a dust control plan as “a long-term st control has proven consistently cost effective. Mine planning has a

ly important role to play in dust control. Applying controls after the problems ten difficult, impractical or costly.”

ds/Unpaved Roads

ust is derived from a variety of sources; nonpoint sources such as un-vegetated specific sources such as haul roads (Environment Australia 1998). Dust can be defined as the process by which particulate matter becomes airborne. nt of dust that becomes airborne is a function of various factors; including the lity of the surface material to wind and water erosion, and the erosive actions cks (Thompson & Visser 2002). If this latter human activity coincides with le weather conditions, the result can be greatly increased dust emissions et al., 1999).

ul roads generate significant amounts of dust emissions (EPA Fugitive Dust, 92; Thompson and Visser, 2002).

e been several studies completed to estimate the emission rates of PM10 on oads. According to Bolander and Yamada (1999) in the US ice Report, Dust Palliative Selection and Application Guide, the following ation factors should be considered when designing a dust control plan:

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Dust Generation Factors:

• Vehicle Speed • Number of Wheels Per Vehicle • Traffic Volume • Particle Size Distribution of the Aggregate • Compaction of the Surface Material • Surface Moisture • Climate

Researchers from the Desert Research Institute at the University of Nevada determined that a vehicle traveling on a untreated unpaved road at a speed of approximately 25 mph generates between 0.59 to 2.00 lbs of PM10 emissions per vehicle miles traveled (VMT) (Gillies et al. 1999). When that vehicle’s speed was increased to 35 mph the emission rates increased to 1.85 to 3.04 lbs. PM10 VMT with an uncertainty of 0.23 lbs. PM10 VMT. Other studies have found similar emission results. Flocchini et al.(1994) suggest that reducing vehicle travel speeds on unpaved roads from 40km/hr to 24 km/hr reduced PM10 emissions by 42 + 35%. The Environmental Protection Agency, reporting in Compilation of Air Pollutants Emission Factors Volume 1 Ch 13, AP-42 (1998), found that emission of fugitive dust on haul roads is highly correlated with vehicle weight and silt content of the surface material. The study reported that a silt content mean of 8.4% of fines on a haul road while a mean of 24% was found on a freshly graded haul road. This indicates a significant increase in fines after a road has been graded.

In addition to these factors the EPA also suggests that other traffic characteristics should be considered; such as the cornering of trucks, the road’s bearing strength, and grade (EPA, 1998, AP-42). They also suggest a complete examination into climate conditions like freeze/thaw cycles and monthly average wind speeds. Effective dust control on haul roads in the Powder River Basin is complicated by the fact that stretches of road, constructed of less than optimal aggregates, are subject to high traffic volume by heavy haul trucks, which requires continuous grading and the frequent addition of new surface material. Wearing of surface material is related to a number of factors including wind speed at the road surface, traffic volume and tonnage, type of road aggregate, compaction of the road, amount of spillage, and climate (Thompson & Visser 2002). In addition to haul roads and related travel areas such as truck parking lots, stockpile/reclaim areas also contribute to total dust emissions, but are usually much more difficult to control. (EPA Fugitive Dust, 1992). The EPA has devised numerous equations to estimate emissions both from unpaved roads and from storage piles. These equations can be found in “Fugitive Dust Background Document and Technical Information Document for Best Available Control Measures,” published by the EPA in September of 1992.

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In a report by the U.S Army Construction Engineering Research Laboratories Gebhart et al.(1999) noted that chemical suppressants should be considered as a secondary solution in controlling dust. “A properly maintained road with adequate drainage to create a hard road surface should be the first step and must be implemented to the greatest extent possible. The best way to avoid a dust problem is to properly maintain the surface, and that is achieved by grading and shaping for cross sectional crowning which prevents dust generation caused by excessive road surface wear.” It should be noted that this study had to contend with heavy vehicles with tracks, such as tanks, which reduced the efficiency and cost effectiveness of any dust suppressant.

Effectiveness of Dust Suppressant Measures on Unpaved Roads When analyzing dust control effectiveness it is hard to determine a product’s direct impact due to the large number of compounding variables (traffic volume, truck weight and speed, road type, etc.). This is further compounded by the fact that there is not a uniform standard for determining dust suppressant effectiveness (North Carolina Department of Environment and Natural Resources Division of Air Quality (2003). Most assessments available are based on qualitative data not quantitative data (Sanders & Addo, 1993). “Without any quantitative dust measurement, it is difficult if not impossible to assess the economics and lasting value of dust palliation methods,” (Sanders & Addo, p.11, 1993). There are generally two areas of study concerning measuring or analyzing dust. The first is atmospheric modeling and prediction, and the second is field measurements and quantificat1993). Field studies are generally more helpful in determining achowever there are numerous factors that need to be considered. of site characteristics, it is difficult to recommend a suppressant situations. In many instances the only gauge of the effectiveness of a produfrom manufacturer’s testing or testimonials from previous users it is hard to determine if the product is going to work in a particudifferent aggregate type.

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Chemical dust suppressants generally provide a PM10 control efficiency of about 80% when applied at regular intervals of two weeks to one month (EPA, AP-42, 1998). The effectiveness of dust suppressants however, depends on the dilution rate, the application rate, the time between applications, the amount, weight and speed of traffic, meteorological conditions, and road characteristics.

ions (Sanders & Addo, tual effectiveness; Because of the diversity that will work well in all

ct is either the results (Engle, 2004). Even then lar area with possibly a

The following is a summary of some of the significant studies that have been conducted regarding the relative effectiveness of dust control measures. Thomas Sanders, et al.(1997) conducted a study at Colorado State University on unpaved road sections in Larimer County, Colorado to try to determine the relative effectiveness of the three commercially available dust suppressants. These researchers evaluated the effectiveness of lignosulfonate (lignin’), calcium chloride (CaCl2), and magnesium chloride (MgCl2) against a section left untreated. They based their evaluation on three fundamental measurements; traffic volume, fugitive dust emissions, and total aggregate loss and used these measurements to calculate a cost analysis. After taking 15 dust samples over a test period of 4.5 months they found that all three of the treated sections outperformed the untreated section. Total aggregate loss was significantly higher for the untreated section, in fact it was 3 times more than the MgCl2, 2.7 times the lignin’, and 2 times the CaCl2. Relative fugitive dust emissions were also highest on the untreated section. Based on cost to replace aggregate lost, traffic volume, cost of maintenance, and cost of suppressants they concluded that lignin’ and MgCl2 had an identical cost per mile per year of $21 vehicle, while CaCl2 was at $26 and the untreated was up to $36. They produced the following chart to highlight the cost analysis. (ADT is the average daily traffic).

(Sanders, et al. p. 396, 1997) Based on these results, the group concluded that under high temperature and low relative humidity lignosulfonate appears to lessen the amount of dust produced. They also found that lignosulfonate and MgCl2 had the least total aggregate loss at 1.0 t/mi/yr/vehicle. The study found a 28-42% reduction in annual maintenance cost for the treated sections compared to the untreated sections.

However, during a personal interview with this author on March 30, 2004, Dr. Sanders stated that he felt the MgCl2 was the superior product based on cost and long term effectiveness (Sanders, 2004).

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In a laboratory study, Epps and Ehsan (2002) compared aggregates from Wyoming, Texas, and Arizona to determine the effectiveness of water, CaCl2 and MgCl2 at controlling dust. They used a crushed gravel stone from Wyoming in one segment of the study. This gravel contained approximately 9.9% fines, less than both the Texas and Arizona samples. They prepped the aggregates by allowing them to cure for 2 days at 32C and 35% relative humidity. They then sprayed the samples with water at a rate of 1.8 L/m2 to reduce the surface tension and increase the rate of penetration, and next applied magnesium chloride to one sample, calcium chloride to another, and water only to another sample. They found that applying chemical palliatives (MgCl2 and CaCl2) to the Wyoming aggregate had a statistically significantly effect on reducing erosion caused by wind. This, they determined was related to the fact that the chemicals kept the surface wet even in windy conditions. The authors found no real difference between the MgCl2 and CaCl2, but noted that both lose their effectiveness over time. Next they evaluated the effectiveness of the chemicals in a simulated traffic experiment. They found that a 38% solution of CaCl2 and a 30% solution of MgCl2 applied to the Wyoming aggregate significantly reduced erosion caused by traffic compared to an aggregate sample that was only treated with water. They concluded that the application of CaCl2 or MgCl2 greatly enhanced dust control on unpaved roads in comparison to water or no treatment and that there is not a significant difference between the two chemicals. Gillies et al. (1999) from the Desert Research Institute at the University of Nevada and the San Joaquin Valley Unified Air Pollution Control District evaluated the effectiveness of four dust suppressants over a 14 month study. The suppressants that were tested included a biocatalyst stabilizer (EMC2), a polymer emulsion (Soil Sement), a petroleum emulsion with polymer (Choerex PM), and a nonhazardous crude-oil-containing material. The study identified an equation to calculate suppressant control efficiency, which they define as “the percent reduction in emissions between the treated and untreated sections:”

Efficiency= 1-(treated emission factor/untreated emission factor)

This study determined that estimating suppressant efficiency can be done using some simple methods in place of expensive monitoring. The authors determined that a measurement of the bulk silt loading and the surface strength can provide an effective and inexpensive assessment of a suppressants effectiveness to reduce PM10 emissions. A suppressant treated surface that can achieve bulk silt content less that 20 g/m2 is considered to be 90% effective at suppressing PM10 emissions. Further, if that surface can maintain flexibility (measured by a penetrometer) and can resist brittle failure then the suppressant is predicted to maintain effectiveness longer (Gillies, et al. 1999).

Effectiveness results The bio-catalyst (EMC2) was only 39% effective one week after the initial application and 0% effective after 11 months. The acrylic co-polymer was 95% effective after one week and approximately 85% after 11 months. The bitumen product was 95% effective after one week, 75% after 3 months, and 53% after 11 months.

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The EPA has created an equation to determine the PM10 emission factor for unpaved roads. This accuracy of this equation, however, is still under some question, particularly related to vehicle speed (Muleski/MRI 2002). Also this equation is designed around average traffic weight, and does not account for heavier trucks (e.g. haul trucks).

E=2.6 (Silt/12)^0.8 (Weight/3)^0.4 / (Moisture/0.2)^0.3)

E = PM10 unpaved road dust emission factor for all vehicle classes Silt = silt content, material less than 75 µm in the surface material Weight = average weight of the vehicle fleet (tons) Moisture = surface moisture content (%) (EPA, AP-42, 1998)

The addition of moisture into the equation is fairly recent (Countess, 2001). It was added based on the recognition that climate and moisture play a large part in overall emissions from unpaved roads. An older version of this equation included variables for the number of wheels and speed, but re-analysis proved the variable not to be statistically significant (Countess, 2001). However, when using this model in an industrial setting it may be important to account for total wheels, traffic volume, and speed as variables. In addition, some feel that the type of aggregate should be included as it can often account for the long term amount of fines in the road surface. Dust Suppressants Road dust suppressants have evolved notably. Second and third generation products are now solving not only the dust problem but also cost efficiency, environmental, and labor issues (Engle, 2004). Positive results are now coming from even the toughest desert and drought environments where past products have failed (Engle, 2004). While EPA (AP-42, 1998) testing has shown that chemical dust suppressants can be effective (80% PM10 reduction when applied at regular intervals) there is not a single, cure-all solution. Some products work better in certain climates, various road surfaces, and under different traffic volumes, and each product comes with various advantages and limitations. Dust suppressants are effective based on the fact that they agglomerate the fine particles in a road surface, binding the surface particles together, and increasing the density of the haul road surface material (Bolander & Yamada, 1999). If fines are lost as dust on an unpaved road it leads to the coarse material coming loose and can then be thrown or washed away. This can result in a road full of corrugations and potholes that require expensive maintenance (Sanders & Addo, 1993). “The main goal of a dust control is to stabilize the road surface; reducing the rate of aggregate loss and money spent annually in replacement,” (Sanders & Addo, 1993). Dust control additives are beneficial not only at reducing dust emissions, but they also improve the compaction and stability of the road. According to Epps and Ehsan (2002) there are numerous factors related to the effectiveness of a dust palliative including application rate, method of application, moisture content of the surface material during application, palliative concentrations fines content, mineralogy of the aggregate, and environmental conditions.

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Surface treatments to control dust emissions fall under two categories, wet suppression and chemical stabilization (EPA, AP-42, 1998). Wet suppression includes watering and the application of surfactants that keep the road surface wet. Chemical stabilization involves an attempt to change the physical characteristic of the road. Unlike watering, chemical suppressants require less reapplication and many act to form a hardened road surface (EPA, AP-42, 1998). The addition of a wetting agent or larger sized particles reduces erodibility only at the interface of the surface and the impact vehicles (Thompson & Visser 2002). Dust control measures lose effectiveness on a scale ranging from immediately to weeks. The palliative effects of water decays from 100% to 0% in a matter of hours while chemicals applied to control dust may decay over several days or weeks so it is important to understand the expected effectiveness of the product that you are working with (Thompson & Visser 2002). A report issued by the U.S. Department of Transportation and the South Dakota Local Transportation Assistance Program states that in areas of high traffic volume, the cost of dust control can more than pay for itself. This is based on the fact that a good dust control agent can not only reduce material lost from the road, but also reduce the need for blade maintenance (Skoreth & Selim 2000). The same study determined that when a dust suppressant is not working well aggregate fines are lost, leaving only gravel size particles on the road, which leads to the formation of a washboard surface, reduced skid resistance, and potholes. The addition of agents (water or chemical) to reduce erodibility is based on the principle of increasing binding of the fines and gravel. (Thompson & Visser 2002). According to “Surface Mine Dust Control” by John Organiscak, et al. (2003), the best dust control plan should be dependent on the type of aggregate you have on your haul road. Selecting a dust suppressant, according to Sanders (1993) should depend not only on its performance characteristics, but also on the type of traffic and volume, roadway conditions, and the costs involved to achieve the desired level of control. In the following selection and application guide, Bolander and Yamada (1999) suggest that selecting suppressants involves determining not only cost but cost effectiveness. They have devised the following list of benefiting factors that should be considered when selecting a dust palliative.

Palliative Factors

• Coherence of the Dust Particles (to themselves or larger particles) • Resistance to Traffic Wear • Aggregate Retention • Long-term Effectiveness

(Bolander & Yamada, 1999)

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Water

Water assists in maintaining the compaction and strength of the road aggregate and reduces the potential loss of road material (Thompson & Visser 2002). Water is attractive because it is seen as a cost effective alternative, however the cost soon escalates with the addition of expensive equipment and operating costs. Data from the EPA’s Compilation of Air Pollution Emission Factors Volume 1, Ch 13, AP-42 (1998) shown here in Figure 1.1 suggests that small increases in moisture content (1 to 2 moisture level) initially results in large increases in control efficiency (from 0% to 75%) but beyond which additional efficiency grows slowly with increased watering (requires 2.5x more water to increase effectiveness to 95%) significantly reducing cost effectiveness at the upper levels. Figure 1.1 Dust Control Efficiency of Water Similarly, a study by Rosbury and Zimmer (1983) found that watering once per hour has an efficiency of 40% in controlling dust, but when that rate is doubled the efficiency increases only by 15% to 55%. Re-application is required at frequent intervals dependent on environmental conditions. Water retention in the Powder River Basin is generally poor due to high temperatures and wind speeds as well as low relative humidity. Increasing

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water scarcity and cost adds to the scenario making water a temporary and typically un-economical solution.

Thompson and Visser (2002), based on the context of the arid South African coal mines, determined the degree of dust control achieved by watering is a function of the amount of water applied, time between applications, traffic volumes, weather conditions, wearing-course material, and the extent of water penetration into the wearing course. They determined that on an average degree of dustiness, a 50% reapplication is required at three hour intervals in the winter and every hour and a half in the summer. These intervals decrease with the addition of weight per vehicle, number of wheels, traffic volume, and climate conditions. Thompson and Visser (2002) also found that traffic volume negatively correlated with total dustiness; which they explained based on observation, that higher traffic volumes led to more compaction of the wearing course and the removal of most loose material on the sides of the road as well as spillage from the vehicle. They also determined that vehicles lower to the ground with many wheels tend to cause an increase in dust based on the increase in wind shear. Precipitation can greatly reduce dust emissions. Normally a rainfall resulting in at least 0.1 inch is assumed to suppress all emissions. However during a hot, dry summer’s day a rain of that same amount may only reduce emissions for hours as opposed to days (Countess, 2001).

Chlorides

Chlorides are salts that act as water attracters and absorbers; as hygroscopic compounds, they draw moisture out of the air to keep the road surface damp, although there is no physical binding (Skoreth & Selim 2000).

Chlorides are the most commonly used products for haul road dust control. A study by Rosbury and Zimmer (1983) showed that the highest control efficiency measured for a chemical dust suppressant (at that time), 82%, was for CaCl2 two weeks after application, then decreased over time. The average during the initial two weeks was approximately 50%. After five weeks, the control efficiency declined to less than 20%.

The most common salts used to control dust are calcium chloride (CaCl2) and magnesium chloride (MgCl2). When determining which is most effective, it’s ability to produce a brine under adverse conditions such as high wind speeds, low humidity, or high traffic volumes is the best indicator (Sanders, 1993).

CaCl2

Calcium Chloride (CaCl2) has been used as a dust control and road stabilizing agent for the last century (Epps & Ehsan, 2002). CaCl2 has deliquescent and hygroscopic properties causing the chemical to have a

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high affinity to water; increasing the tension of water molecules between soil particles. When applied the chemical increases the adhesive bond between particles resulting in retention of particles. According to Epps et al.(2002) CaCl2 has a wider range of effectiveness in regards to temperature than magnesium chloride and loses its hygroscopic property at a temperature of 25C if the relative humidity drops below 32%.

Calcium Chloride comes in three forms; flake at 77-80% purity, pellet 94-97% purity, and a clear liquid at 35-38% purity (Bolander & Yamada, 1999). Calcium Chloride is favored over Magnesium Chloride in areas or seasons of higher humidity, but it is not as effective in long dry spells (Bolander & Yamada, 1999). This chemical can significantly lower the freezing point of a water solution. In fact at 30% solution can have a freezing point of -60F (Larkin Laboratory, 1986). Because of this property several coal mines choose to use CaCl2 during the winter.

MgCl2

Magnesium chloride is a by-product of potash production and is only available in the liquid form (Ferguson et al., 1999). When determining if CaCl2 or MgCl2 is more effective there are contradictory findings and statements. It seems the more recent studies are coming to the conclusion the MgCl2 is outperforming CaCl2,. According to Epps and Eshan (2002) MgCl2 is more effective than CaCl2 in increasing the surface tension of water molecules. Bolander and Yamada (1999) found that MgCl2 is considered to be the best water absorbing product for drier climates because the chemical starts to absorb water from the air at 32% relative humidity regardless of the temperature. The product also increases the aggregate surface tension, creating a very hard road when the surface is dry, more so than CaCl2.

Both CaCl2 and MgCl2 are known to be corrosive to metals, because they attract moisture to the surface and thus prolong the period of erosion (Bolander & Yamada, 1999). A positive attribute of both of these chemicals is that each allows a maintenance crew to re-grade and re-compact with little concern for surface moisture loss.

Gebhart et al.(1999) state that these salts provide the most satisfactory blend of application ease, cost, and dust control for semi-arid, semi-humid climates. Organic/Non-Bituminous Chemicals

Compounds under this category include lignosulfonate, sulphite liquors, tall oil pitch, pine tar, and vegetable oils. These products generally perform well in arid environments but are not very effective when applied to aggregate surface material with few fines (Gebhart, et al., 1999). These dust control agents can be

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very sticky and may harbor an unappealing odor. They often fail after heavy rains due to their water soluble, organic nature (Gebhart, et al., 1999). These products currently appear expensive, but the cost benefit equation continually changes. As a rule, they tend to be environmentally friendly. One compound with some supporting literature is lignosulfonate (lignin’).

Lignin’

Lignin’ or lignosulfonate is a by-product of the paper making process and is regarded to be generally safe environmentally because of the fact that it is an organic product. This product performs very well under arid conditions. It binds particles together to increase the strength of the road and remains effective during long dry spells with low humidity (Bolander & Yamada, 1999). One of lignin’s weaknesses is that it is highly soluble in water, and its surface binding properties can be destroyed by heavy rain. It also has a tendency to stick to passing vehicles and is difficult to remove from painted surfaces (Frazer, 2003). Lignin is most effective and shows the greatest longevity when the road has been scarified and the product has been mixed into the aggregate (Sanders & Addo, 1997). However, it is this same scarification process that reduces the current use of lignin’ on some haul roads, as the perceived costs of the down-time due to scarification and curing appears prohibitive.

A study using lignin’ on Pikes Peak’s unpaved roads conducted by Sanders and Addo (1998) revealed that the lignin was 2.7 more effective at suppressing dust than water. After spring snowmelt, 8 months after application, there were indications that the Lignin’ was still functioning in a good proportion of the test sections.

Petroleum Products

Petroleum products include asphalt emulsions (modified and not), dust oils/dust fluids, and petroleum resin emulsions. These products may be effective in a variety of climates; however, because they are by-products of petroleum and waste oils, they may contain toxic materials with significant environmental effects, and are not considered safe unless they have been processed to remove toxins (Gebhart, et al., 1999). These products are usually very expensive and like the organic products, are very sticky and have a foul smell. Petroleum products are film forming and dust binding. They coat the dust particles and form a cohesive membrane that attaches each to adjacent particles. This results in a chained bond of large agglomerates that are too heavy to be dislodged by wind (James Informational Media, Inc., 2000).

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Emulsified Asphalts

Emulsified Asphalts work to control dust, but their use is very limited and the product must be applied with specialized equipment (Skorseth and Selim 2000). The soil type and density of the road surface can greatly affect the rate at which a petroleum product penetrates the road. Roads that have been scarified to loosen the aggregate achieve the greatest amount of soil penetration. If the road has not been scarified the use of products with low viscosities will be ineffective (Bolander, Yamada 1999).

Polymers

Polymers such as polyvinyl acrylics and acetates work by binding the surface particles together to form a semi-rigid film on the surface. Polymers are considered suitable for use under a wide range of climate and soil conditions and are most effective in environments that receive 8 to 40 inches of precipitation a year. Generally, a light compaction of the road after application of a polymer is recommended unless the product is mixed into the road surface (Bolander, Yamada 1999). Polymers are considered to be most effective on lightly trafficked areas. These types of palliatives are usually non-toxic and environmentally friendly (Gebhart, et al., 1999).

Electro-Chemical Stabilizers Electro-Chemical stabilizers include sulphonated petroleum, ionic stabilizers

and bentonite. They are not likely to leach out and are stated to be very effective at reducing dust emissions in clay or sandy aggregate types. These products work well under a variety of climate conditions; however, many of these products have not been tested using standard laboratory tests under field conditions. Small scale trials should be performed to determine site specific efficiency prior to larger scale usage (Gebhart, et al., 1999).

Surfactants Essentially surfactants are additives that make water wetter, reduce surface tension and allow better penetration of the palliative. At least one product (Haul Road Dust Control) claims a cumulative effect, whereby each new application boosts the effectiveness of the previous levels. Several manufacturers of surfactants recommend prewetting of the roadbed, for their products to perform optimally. Similarly, Epps and Ehsan (2002) used prewetting in their laboratory study of aggregates and erosion. There is a slight trend within mine operations in the Powder River Basin to use highly diluted applications of MgCl2 and CaCl2 in all water applications, instead of a surfactant.

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There are environmental concerns associated with the use of certain surfactants. (refer to page 17 of this document for a discussion of these impacts) Other Commercial Products

A list of commercial products is posted by The New Mexico Environment/ Department of Air Quality Bureau, which can be accessed on the web at http://www.nmenv.state.nm.us/aqb/dust_control.html and in Table 3.1 of this report. There are some products listed here that are not included in this literature review. Classification of every product is not possible in part due to lack of a literature history and to the proprietary nature of the commercial formulas. Mechanical Stabilization Mechanical or road stabilization is the mixing of two or more substrate materials to create a road surface that has the correct fine gradient and plasticity. This method does not involve the application of chemicals although they can be used in addition to the stabilization. One of the most effective substrate mixtures involves the addition of clays to a gravel and sand aggregate. The clay binds to the fine particles, and improves the roads stability and longevity. “When a gravel road resists lateral displacement during traffic, it is said to be mechanically stable, notes Gebhart, et al. (1999). This resistance is provided by the natural forces of cohesion and internal friction that exist in the soil.” Importance of Appropriate Dust Suppressant Application Appropriate application of a selected product is key to the overall effectiveness of a dust control plan. “It can translate either into success or costly wastefulness, failure, and more difficult maintenance down the line,” according to David Engle (2004), author of “Road Maintenance Techniques and Products Have Made Great Strides.” Engle also emphasizes timing as a critical component to successful application. He suggests an initial application during the narrow window between the spring rains and the start of the summer drought; “Keeping an eye on the weather forecast is critical; many expensive applications have been ruined by rainfall.” Not only is the timing of the application crucial, but the manner in which the product is applied is just as important - if not more so. Sanders and Addo (1993) describe two ways in which suppressants are most typically applied; mixed-in-place and spray methods. The mixed in place method involves mixing the suppressants with the road aggregate. When this application procedure is used it not only suppresses dust but it also provides for an improved road surface resulting in reduced maintenance costs. Spraying involves the high pressure application of the material to the road surface. Topical spraying is effective for short periods of time, though, resulting in the need for reapplications throughout the season (Sanders & Addo, 1997). It is usually wise to try a test section to determine how well the product is going to work on a specific gravel, and what type of application works best (Skorseth & Selim, 2000).

Almost all suppressants have a greater longevity and effectiveness when applied to a road that has been properly prepared, scarified, and the suppressant is mixed in with the aggregate and then compacted to a 6-inch thick wearing course (Sanders & Addo, 1997).

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Another key application principle was identified by Bolander and Yamada (1999). They suggest that adequate penetration of the dust suppressant into the surface material is imperative. This penetration should be 3/8 to 3/4 of an inch in depth. Proper penetration will reduce the loss of palliative from surface wear and allow the surface to resist leaching. The process imparts cohesion, and resists aging. Bolander and Yamada (1999) in the USFS Dust Palliative Selection and Application Guide, provide the following suggestions for applying dust suppressants:

Application Tips

• Repair unstable surface, grade (to a adequate depth) immediately prior to application

• Apply suppressants (especially salts) immediately after the wet season • Apply after a rain, or spray the road before application, to ensure

materials are more moist and thus more workable • Adhere to manufactures recommendations on minimum application

rate, compaction and curing time • Use a pressure distributor to evenly distribute the suppressant • Water frequently and lightly, not infrequently and heavily

Scarifying Sanders et al. (1997) include scarification of the road surface in their list of important techniques to be considered when applying dust suppressants and particularly specify the technique when using lignin. Organiscak et al. (2003) suggest that when using chlorides it is beneficial to loosen 1-2 inches of the road aggregate uniformly to allow the chemical to penetrate evenly. And like Bolander and Yamada (1999), the group stresses proper road preparation as a key to the effectiveness of a dust palliative, especially creating a good crown and drainage when using a chloride. They also state that when using a chloride the roadway should not be compacted before applying the chemicals and the road should be kept at optimum moisture before application, this allows the product to be absorbed quickly and evenly.

For some suppressants it is recommended to keep traffic off the road surface for two to three hours after application to allow the product to absorb and cure (Skorseth & Selim, 2000). This characteristic is expected to be considered a limitation by mine engineers, who would have difficulty justifying the necessary down time involved on mine haul roads (see survey results, Appendix A). Grading after application also partially destroys the effect of many dust suppressants (Ferguson et al., 1999). Because of this, grading should be postponed after heavy application of suppressant for as long as possible. The EPA has recommended that a diluted reapplication be applied periodically (2 weeks to a month) to control loose surface material. They also state that weather related

15

application schedules should be considered prior to implementing a dust control program (EPA Fugitive Dust, 1992). The type of road aggregate is one factor that determines the type of dust control that is most effective. Organiscak et al. (2003) recommend effective applications for various road types in their article “Surface Mine Dust Control.” In road surfaces with poor size gradation, water is the only effective solution because chemical suppressants (most of which are water soluble) cannot compact the surface or form a new surface because they will leach. In sand they recommend bitumens because of the fact that they are not water soluble. On a road with good gradation all chemical suppressants can be used, and on a road with too much silt the road should just be rebuilt, as no dust control will be effective (Organiscak, et al., 2003). If a haul road is left untreated by a dust suppressant aggregate replacement will become necessary over shorter periods of time and maintenance will be required more frequently (Epps & Ehsan, 2002).

Education and Training

In addition to using prescribed application procedures, John Watson and Judith Chow (2000) from the Desert Research Institute suggest that the success of a dust control problem depends on outreach and education programs for contractors and public works agencies. In a coal mine, education should be extended to maintenance personnel.

Environmental Impacts The major environmental concern when using dust suppressants is contamination of ground and surface water. Thomas Piechota, an assistant engineering professor at University of Nevada Las Vegas was quoted in Lance Frazer’s “Down with Road Dust (Innovations)” as saying it doesn’t matter what suppressant is used, there will always be some level of water quality impact (Frazer, 2003). Peichota noted that petroleum compounds were more harmful than suppressants such as magnesium chloride. Another area of impact he mentioned is the fact that the suppressants are creating a somewhat impenetrable road surface, which will increase runoff, which has its own hydrologic impacts. There is some potential for off-site plant damage during periods of heavy rainfall (Ferguson et al., 1999). All necessary precautions should be followed to unsure that these chemicals are kept away from water sources.

16

The following photo taken in June of 2004 in Larimer County, Colorado between Lyons and Estes Park strongly suggests runoff from a highway treated with a 30% solution of Sodium Chloride (rock salt) and sand may be impacting ponderosa and other pines (Anon’ CoDOT, 2004).

While no Wyoming coal mines use Sodium Chloride to treat dust on haul roads that we know of, the expected negative publicity from this environmental impact (near Boulder) may carryover into other road salts such as MgCl2 and CaCl2 which are heavily used. There is no scientific evidence yet of the actual cause of the tree damage, but the die-off appears to be confined to an area within 50’of the roadway for 20 plus miles, strongly suggesting road runoff and/or exhaust fumes as contributing factors. Conversely, few Wyoming coal mine haul roads traverse timbered acreage, limiting this specific impact. Surfactants, on the other hand, may pose some environmental concerns. M. Warhurst (1995) in a report to Friends of the Earth, England, outlines toxicity concerns with alkylphenol ethoxylate (APEO) surfactants, and calls for a more widespread ban on their use (The surfactant is currently banned in several European countries). He recommends the replacement of APEOs with linear alcohol ethoxylate surfactants, which are readily biodegradable according to Consultants in Environmental Sciences Ltd (CES, 1993).

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Works Cited

Anonymous Colorado Department of Transportation Official. Personal Interview with Author. June, 2004. Boulder, CO. Bolander, P., Yamada, A. (November 1999). “Dust Palliative Selection and Application Guide.” United Department of Agriculture, Forest Service, Technology and Development Program. San Dimas Technology and Development Center, San Dimas, California. Countess, R. et al. 2001. Methodology for Estimating Fugitive Windblown and Mechanically Resuspended Road Dust Emissions Applicable for Regional Air Quality Modeling. Paper in International Emission Inventory Conference, "One Atmosphere, One Inventory, Many Challenges." Denver, CO, April 30. (Power point presentation slides) Engle, D. (2004). “Bidding Farwell to Dusty Roads, Road Maintenance Techniques and Products Have Made Great Strides,” Forester Communications, Erosion Control January/February 2004. www.forester.net Environment Australia, Department of the Environment and Heritage (1998). “Dust Control Best Practice Environment Management in Mining.” Sustainable Industry/Sustainable Minerals. Environmental Protection Agency 450/2-92-005 (1992). “Fugitive Dust Background Document and Technical Information Document for Best Available Control Measures.” Office of Air Quality, Planning and Standards, Research Triangle Park, NC. Environmental Protection Agency (1998). “Compilation of Air Pollution Emission Factors, AP-42. ” Volume 1, Ch 13, Unpaved Roads. Office of Air Quality, Planning and Standards, Research Triangle Park, NC 27711. Epps, Amy, Ehsan, M. (2002). “Laboratory Study of Dust Palliative Effectiveness.” Journal of Materials in Civil Engineering. September/October 2002 p.427-435. Frazer, Lance (2003). “Down with Road Dust (Innovations),” National Institute of Environmental Health Sciences. Env Health Perspectives Dec. 2003 V111 i16 pA892(A). Ferguson, J.H. et al. (1999). “Fugitive Dust: Nonpoint Sources.” Agricultural MU Guide. University of Missouri-Columbia. Agricultural Publication G1885. Gebhart, D.L., Denight, M.L., Grau, R.H., (1999). “Dust Control and Technology Selection Key.” U.S. Army Construction Engineering Research Laboratory, Land Management Laboratory, Resource Mitigation and Protection Division; and the U.S. Army Engineer Waterways Experiment Station, Pavements Division. James Informational Media, Inc (2000).“Better Roads, a Look at Dust Control and Road Stabilizers.” Better Roads Magazine www.betterroads.com/articles/prod500.htm

18

Larkin Laboratory (1986). “Calcium Chloride and Magnesium Chloride for Dust Control.” 1691 N. Swede Rd. Midland Michigan 48640 N. Carolina Department of Environment and Natural Resources Division of Air Quality (2003). “Economic Analysis of Particulates from Fugitive Dust Emissions Sources.” Organiscak, J.A., et al. (2003). “Chapter 5. Surface Mine Dust Control.” In Handbook for Dust Control in Mining, Center for Disease Control, IC # 9465. Rosbury, K.D., Zimmer, R.A. (1983). “Cost-Effectiveness of Dust Controls Used on Unpaved Haul Roads, Volume 1: Results, Analysis, and Conclusions.” PEDCo Environmental, Inc. U.S. Bureau of Mines. Sanders, T. (2004). Personal Interview conducted by Temple Stevenson on the campus of Colorado State University, March 30, 2004. Sanders, T.G., Addo, J.Q. (2000). “Experimental Road Dust Measurement Device.” Journal of Transportation Engineering, November/December 2000. Sanders, T.G., Addo, J.Q. (1998). Pikes Peak Road Dust Project. Colorado State University. Sanders, T., Addo, J.Q., Ariniello, A., Heiden, W.F. (1997). “Relative Effectiveness of Road Dust Suppressants.” Journal of Transportation Engineering September/October 1997. p 393-397. Sanders, T.G., Addo, J.Q. (1997). “Effectiveness and Environmental Impact of Road Dust Suppressants.” MC Report NO. 94-28, Mountain Plains Consortium. Skorseth, K., Selim, A.A (2000). Gravel Road Maintenance and Design Manual. South Dakota Local Transportation Assistance Program. U.S. Department of Transportation, Federal Highway Administration. Thompson R.J., Visser, A.T. (2002). “Benchmarking Management of Fugitive Dust Emissions From Surface-Mine Haul Roads.” Transaction of the Institute of Mining and Metallurgy, 111/April, pp A28-A35. Watson, J.G., Chow, J.C. (2000). “Reconciling Urban Fugitive Dust Emissions Inventory and Ambient Source Contribution Estimates: Summary of Current Knowledge and Needed Research.” Desert Research Institute, Energy and Environmental Engineering Center. DRI Document No. 6110.4F Wyoming’s Long Term Strategy for Visibility Protection- Review Report. 2003. Prepared by the Wyoming Department of Environmental Quality, Air Quality Division

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II. Recommended Practices and Best Available Control Measures Best practices for dust control in a Wyoming surface coal mine simply means utilizing the most practical and effective methodology that is currently available. In many cases best practices can be achieved by appropriate planning and or the identification and control of dust sources as they are identified. According to “Dust Control Best Practices Environmental Management in Mining” prepared by Australia’s Department of the Environment and Heritage, best practices for dust control in a surface mine operation should include: Planning

The identification of potential sources of dust A prediction of dust levels likely to occur An evaluation of the effect of the dust The incorporation of the dust predictions and control measures into mine planning

and design

Observation

Observations of point sources which can be readily identified Dust emission rates based on qualitative estimates and models

Controlling

An aware workforce Integration of dust control into operations planning (construction, topsoil

stripping, blasting) Intergrading dust control provisions into work practices (use of chemical

palliatives) Monitoring and feedback dust emissions Efforts based on observational and qualitative assessments Awareness of current methods and technology used for dust control

(Environment Australia, 1998, p.8-9)

The most effective, consistent and cost effective dust suppression strategy is a long term plan that looks to control dust before the problem arises. Applying dust controls after the problem arises is impractical and costly. Because of this, mine planning has a very significant role to play in dust control (Environment Australia, 1998).

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Dust Control Strategies When developing a dust suppression plan there should be a set of standardized procedures for application and maintenance. Standardized application this will minimize confusion on how the product is applied and maximize the product’s effectiveness. A sound set of road application and maintenance procedures will result in safer working conditions, a decrease in actual maintenance work, in addition to a decrease in overall road dust emissions. The following quote prepared for the U.S. Army Construction Engineering Research Laboratories, highlights the fact that controlling road dust emissions should be seen as a process, not just the application of chemical palliatives. GebConPalli Con Gooerosdeteet alto pr

Creacausfailu

“The best way to avoid dust problems is to ensure that roads are properly maintained by surface grading and shaping for cross-sectional crowning to prevent excessive road surface wearing and consequent dust generation. Chemical dust suppressants are considered a secondary solution, to be used only when maintenance practices have been implemented to the greatest extent possible,” (Gebhart, et al. 1999, p. 10)

hart, et al. (1999) recognize three major types of dust control methods including: (1) struction and Maintenance; (2) Mechanical Stabilization; and (3) Chemical atives.

struction and Maintenance

d construction and maintenance practices are fundamental to providing durable and ion resistant trafficked surfaces in dust-prone areas. Due to environmental and traffic rioration of the aggregate surface haul roads require frequent maintenance. Gebhart, . (1999) suggest that the following construction and maintenance steps be performed event dust emissions on unpaved roads:

Use of a well graded aggregates consisting of an adequate amount of fines that can be used as cohesive binders. Retention of a crown on the road surface to provide adequate drainage. Drainage for the wearing surface, shoulder, and verge. Proper compaction of the wearing surface after the addition of aggregate and

grading. Reduced maintenance grading during dry weather conditions.

ting adequate surface drainage should be provided in order to minimize damage ed by moisture. Standing water in the roadway will lead to surface softening and re (Skorseth, Selim 2000).

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Compaction of the road after adding aggregate and grading will increase the density and strength of the wearing surface as well as retention of larger aggregates (Gebhart, Denight, Grau, 1999).

Mechanical stabilization A road is considered stable when it resists lateral displacement caused by traffic. Mechanical stabilization is achieved by mixing soils of two or more gradations. This type of resistance is attributed to the natural forces of cohesion and the internal friction that are present in the soil (Gebhart, et al. 1999). Dust control products often have an added benefit of increasing soil stabilization. According to Skorseth and Selim (2000) in “Gravel Road Maintenance and Design Manual,” soil stabilization will control the loss of fines from the road surface that typically result in distresses such as wash-boarding and reduced skid resistance. This type of unstable road becomes hard to maintain and hauling in new road aggregate with a higher percentage of fines becomes expensive. Aggregate loss can be as much as one ton of aggregate per mile per year on a typical unpaved county road for each vehicle that passes over a road daily (Sanders, Addo, 1998) and losses would be substantially higher on haul roads. A reduction in blade maintenance is another benefit of using a dust control product. When the road remains tightly bound and stable it will require less maintenance (Skorseth, Selim 2000). Manufactures recommend a delay in blading for as long as possible once a product has been applied because blading can reduce or remove the dust control product from the road. Chemical Palliatives The use of chemical palliatives should be used in conjunction with the two other methods, especially if mechanical stabilization is cost-prohibitive and high dust emissions persist. When chemical dust palliatives are maintained over a long-term basis there can be a 50-75% or more reduction in dust generation. Gebhart, et al. (1999) feel that the dust control methods should be applied in the order discussed here: (1) construction and maintenance, (2) mechanical stabilization, and (3) chemical palliatives in order to reduce dust emissions successfully.

Applying Chemical Palliatives

Before applying any dust suppressant, at minimum basic road maintenance needs to be performed. Preparing a road before the application of chemical palliatives should include the construction of a good crown on the driving surface, good shoulder drainage, and a fresh blading of the road surface to remove any potholes or other imperfections (Skorseth, Selim 2000). In addition scarifying the road in order to loosen the soil a minimum of one to two inches can be done. This will leave a uniform depth of loose aggregate across the road will allow even and fast penetration of the dust control product into the road surface. Several authors and product distributors have cited the need for scarification because of the added depth of saturation it can provide. This deeper saturation is directly related to increased dust control effectiveness. Although there may be some added costs and

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time associated with scarification, in the long run it is generally believed the extended life and increased effectiveness of the product outweighs the initial application preparation costs. The following list is a compilation of recommendations by Bolander and Yamada (1999) for applying dust control products from numerous authors and product distributors.

Suppressant Application Tips

• Repair unstable surface, grade (to a adequate depth) immediately prior

to application • Scarify the road to loosen the surface material to allow for even

penetration of the product into the soil • Apply suppressants (especially salts) immediately after the wet season

(apply directly after a rain or pre-wet the surface prior to application) • Adhere to manufacturer’s recommendations on minimum application

rate, compaction and curing time • Use a pressure distributor and realign the water nozzles on the

application truck to ensure a even distribution of the suppressant • Water frequently and lightly, not infrequently and heavily

Water as a Palliative and its application

Applying water on problem areas provides immediate but short term results. This inexpensive method of dust control is recommended as a short-term solution to dust emission problems (Gebhart, et al.,1999). Water is effective at controlling dust emissions because the water surrounds and adheres to the dust particle making it difficult for the dust particles to move. However, under continual wetting conditions a pumping of the fine to the roads wearing surface may occur (Gebhart, et al.,1999). Excessive moisture on unpaved roads can lead to negative effects including a reduction in the strength of the road bed, road deformation under vehicle loading, and an increased potential for brittle failure which produces smaller particles that can then be crushed by vehicle tires (Rosbury and Zimmer, 1983). In the EPA’s Compilation of Air Pollution Emission Factors Volume 1, Ch 13, AP-42 (1998) it is noted that small increases in moisture content result in large increases in control efficiency, but only up to a point, beyond which additional efficiency grows slowly with increased watering. Water droplet size has been shown to be an important factor in dust suppression effectiveness (Gambatese, James 2001). If water droplets are too large, smaller dust particles generally just slipstream around the droplets without actually making contact. If the droplets are too small they just mix and circulate with the dust particles without actually wetting them. Small droplets may be negatively affected by wind and surface tension. An optimal water droplet size for surface impaction of fine

24

particulate agglomeration is approximately 500 um. To create an effective water spray system hollow cone nozzles which produce the greatest control of dust while minimizing clogging should be used. Angling the nozzles on the truck body in a horizontal angle or lower will protect the droplets from wind.

Application practices issues There can be other problems that inhibit the effectiveness of using a dust control palliative. These include a lack of communication between water truck operators, applying a product where not needed (such as shoulders and berms), and confusion as to the desired outcome of using the product. The information in the following chart is taken from a presentation prepared by Rose Haroian, Environmental Manager for the Powder River Coal Company; and is helpful in addressing some of the operational problems that are encountered when using a dust palliative and or water to suppress dust.

Table 2.1 Dust Control Operations Recommendations Problem Solution Water trucks aren’t synchronized Communicate between water trucks to determine

where watering has and hasn’t taken place

Operators are seeking dust elimination rather than dust control

Maintain an understanding of what the desired goal of watering is, and have indicators that determine when the roads need watered. Sometimes the visual indicators are not accurate.

Roads treated with dust control products are being watered too much

Newly treated roads only need water when they become visibly dusty.

Coal Dust caused by spillage Do not attempt to apply water to coal spills, clean up the spillage instead

Over watering creates more dust Communication needs to occur between the blade and water truck operators, don’t water where it is not needed

Spraying water in high wind Adjust speed and location on the road to account for wind.

Soft Spots Don’t over water, spot watering in the same location will cause road problems

Sprayers are not properly positioned Modify sprayer locations to ensure the angles are optimizing the desired spray area

Watering inappropriate areas such as berms Watch where you are watering. Relocate if needed. If this does not work turn off the outside sprayer.

Blades blade off watered areas Blades should only blade where it is necessary

Blades blade rock and chemicals into ditches Carry windrows across the road. Do not leave chemicals and scoria in the ditch

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Real Time Data - Monitoring Visual indicators to perceive dust emissions problems are a useful technique, however it is hard to keep an eye on dust emissions 24 hours a day. The collection of real-time dust emission data from air quality monitors is important. A reliable PM10 emission inventory is required for the state’s SIP and is logical so that source specific dust control measures can be taken. The dust may be coming from an overburden pile or a county or coal bed methane (CBM) road, so automatic watering of the haul road would be inappropriate. The use of real-time data incorporated with the notification of personnel and a record of where the dust is coming from as well as weather conditions can create can create a higher understanding and accountability of dust emission exceedences. The monitoring network for particulate emissions in the Powder River Basin is extensive; operating since 1989, according to Wyoming’s Long Term Strategy for Visibility Protection: 2003 Review Report (Wyo DEQ, 2003). Additional monitoring, including that of meteorological data is conducted at IMPROVE (Interagency Monitoring of Protected Visual Environments) locations. Figure 2.1 illustrates a sample protocol used by one mine to be followed based on various types of exceedences and events (aided by real-time data).

Air Event

If ug/m level = 300 (over 1 hr) (1) notify product Supervisor ens rec ens notIf ug/m level = 80 (24 hr rolling aver (1) notify product Supervisor Sam Est Co Ins Do Do Ta NoIf ug/m level = 100 (24 hr) (1) Notify Operat eng (2) Notify Genera If ug/m level=150 (excursion event)

(1) Notify the ___(2) Contact the W

Actions to Cu Co Wa DoIf ug/m level=120 (24 hr) (1) Notify same a Contact ____ Contact ____ Contact the W

Figure 2.1 Sample Air Event Outline: Logging and Action Levels (_____________Mine, WY)

ion supervisor ’s actions include: ure adequate water trucks operating ord water usage for this shift ure problem areas are addressed ify____________________ age) ion supervisor ’s actions include:

e as above, plus: imate wind speed and direction nsider modifying plant operations contributing to dust pect dust generating segments of operation to ensure proper dust control cument conditions including offsite impacts, meteorological conditions cument actions taken ke photographs to document primary sources of dust (on or off site) tify Senior Environmental Engineer if cause of dust event cannot be identified

ions Manager(OM), who will notify Sr. environmental ineer (SEE)and production coordinator(PC). l Manager (GM) if curtailment of operations is expected

_ Environmental Manager as well as OM, SEE, and PC, and GM. yoming Dept of Environmental Quality by phone

consider rtail production operations ntact neighbors contributing to dust impact (county roads, landowners ter/suppress dust on any identified problem areas cument actions taken

s above (150 level) Environmental Manager President

yoming Dept of Environmental Quality by phone

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Properly applying and maintaining a dust control product can be more important than selecting the perfect one because the manner in which a product is used directly relates to how effective the product will be. Cost-effective dust control depends not only on application but also on proper maintenance and regular reapplication. Properly using a dust control product can reduce the amount of grading that is required, decrease the amount of road aggregate that is lost, and reduce vehicle wear and tear. Ultimately all of these benefits result in a savings of time and money, which is illustrated in Table 3.2 of this manual. A BACM recommendation from Dona An~a County, New Mexico (2000) can be summarized as Smart Timing and involves the timing of either operations or palliative application so as to prevent the most likely exceedences due to meteorological conditions. The Arizona Department of Environmental Quality (ADEQ, 2001) notes that technological and economic feasibility is a valid criteria for determining BACM and adds that BACM will change as new products and approaches are proven technologically and economically feasible. Gaffney and Shimp (1997), in a report for the California Air Resources Board, call for improved GIS technology to calculate and spatially analyze emissions. In compiling BACM recommendations, the author visited with mine engineers. To ascertain the opinions of surface coal mine engineers in the Powder River Basin relative to dust suppression on haul roads a survey was developed and distributed. Five responses were recorded and are summarized in Appendix A. of this report.

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Best Available Control Measures (BACM) Recommendations The following control measure recommendations have surfaced from a thorough review of the literature and analysis of the fugitive dust situation facing Wyoming surface coal mines. Mine representatives, agents from the Wyoming Dept of Environmental Quality, and Region 8 of the EPA, and other appropriate parties should review and discuss the strategies for technological and economic feasibility and expected effectiveness before a final BACM list is completed.

Table 2.2 Best Available Control Measures - BACM (Recommendations) For Controlling Fugitive Dust on Mine Haul Roads

Keywords Recommended Practice Monitoring Reporting

Develop a protocol (similar to example given in Figure 2.1) for notification of appropriate plant personnel and environmental agencies (e.g. Wyoming Department of Environmental Quality) in reaction to various dust events.

Monitoring Reporting

Develop a report template for documenting and reporting dust events

Controlling Be prepared to supplement current water truck fleet with rental/vendor trucks to ensure no exceedences occur

Inventory Monitoring

Use real time g/h TEOM samplers to make adjustments in mine operations as necessary

Controlling, Documenting

Develop a chemical suppressant regimen that effectively and consistently controls dust. Be prepared to justify this regimen by monitored and documented use to determine effectiveness at varying climatic conditions. Become aware of emerging technologies.

Documenting controlling

Closely document water usage along with climatic conditions (current effectiveness of water is hard to determine due to lack of reliable data)

Communication Share successes and failures with other mine engineers, as dust is a regional issue, not a site issue. training, communication

Periodically conduct personnel appropriate training in dust monitoring and suppression. Ensure communication across all levels of operation.

Monitoring Maintain at least one person on site who is certified in opacity monitoring or contract with a vendor certified in opacity monitoring

Modeling Seek to prevent dust rather than react to it. Include weather forecasting into dust event predictions Incorporate GIS modeling into dust control planning.

Controlling Maintain equipment in optimal condition (e.g. spray nozzles) Controlling Follow proven or recommended palliative application procedures (e.g. surface prep, application

rates and times, curing, compaction and grading) Controlling Take action to reduce spillage from haul trucks, as coal and overburden spillage destabilizes the

road and significantly reduces the effect of palliatives. Maintain optimal roadbed conditions.

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Works Cited Bolander, P., Yamada, A. (November 1999). “Dust Palliative Selection and Application Guide.” United Department of Agriculture, Forest Service, Technology and Development Program. San Dimas Technology and Development Center, San Dimas, California. Dona Ana County, New Mexico. (2000) “Suggested Best Available Control Measures (BACM) for Reducing Windblown Dust from Manmade Sources in Dona Ana County.” Report. Environment Australia (1998). “Dust Control Best Practices Environmental Management in Mining.” Australia Government, Department of the Environment and Heritage. www.deh.gov.au/industry/industry-performance/minerals/booklets/dust/dust1.html Gaffney, P., Shimp D. (1997). “Improving PM10 Emission Inventories.” Report to California Air Resources Board, Technical Support Division. Gambatese, John A., James, David E. (2001). “Water Suppression Using Truck-Mounted Water Stray Systems.” Journal of Construction Engineering and Management V. 137 n1. Gebhart, D.L., Denight, M.L., Grau, R.H., (1999). “Dust Control and Technology Selection Key.” U.S. Army Construction Engineering Research Laboratory, Land Management Laboratory, Resource Mitigation and Protection Division; and the U.S. Army Engineer Waterways Experiment Station, Pavements Division. Haroian, Rose, and Best Practices Team (2003). “Haul Road Dust Suppression, Key Issues and Solution.” Powder River Coal Company. Rosbury, K.D., Zimmer, R.A. (1983). “Cost-Effectiveness of Dust Controls Used on Unpaved Haul Roads, Volume 1: Results, Analysis, and Conclusions.” PEDCo Environmental, Inc. U.S. Bureau of Mines. Sanders, T., Addo, J.Q., Ariniello, A., Heiden, W.F. (1997). “Relative Effectiveness of Road Dust Suppressants.” Journal of Transportation Engineering September/October 1997. p 393-397. Skorseth, K., Selim, A.A (2000). Gravel Road Maintenance and Design Manual. South Dakota Local Transportation Assistance Program. U.S. Department of Transportation, Federal Highway Administration. Thompson R.J., Visser, A.T. (2002). “Benchmarking Management of Fugitive Dust Emissions From Surface-Mine Haul Roads.” Transaction of the Institute of Mining and Metallurgy, 111/April, pp A28-A35.

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30

III. Dust Suppression - Selection Guides

The information supplied throughout this section is intended to provide a convenient resource for the reader, so as to serve as a starting point for a discussion of various features and applications of dust suppressants. The data are not necessarily comprehensive or complete. It is the user’s responsibility to thoroughly research and compare products and vendors to determine which can provide high quality results and services. Vendors are not equally reliable, or comparable, relative to timeliness, price or their adherence to recommended application procedures. It is also the user’s responsibility to determine the extent of environmental impacts associated with a given product or application procedure. A vendor’s claim of non-toxicity should not be considered rigorous proof. As a rule, there is a lack of detailed studies on dust suppressant effectiveness and their impact on the environment and human health (Frazer, 2003). It is not the intent of this document to endorse any product or vendor and any that have been referenced were cited only because of their willingness to provide published information.

TABLE 3.1 DUST SUPPRESSION PRODUCTS, is a compilation of known products, categories and types, as well as contacts where more information on the product can be located. Selection of a dust control product should include a consideration of the manufacturer’s recommended application procedure. Many times a product is not selected if it requires extensive application procedures that under the normal operations of a coal mine cannot be performed. Examples of such procedures include extensive road preparation causing a cessation of operations and/or a prolonged curing time. Additional selection criteria for dust palliatives should include how the product will perform under high traffic volume and weight, site specific weather conditions, length of time the product will be effective, how it works on different types of aggregates, effectiveness on steep slopes, and in extreme temperatures, and other criteria depending on individual needs.

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32

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Bentonite Bio Cat 300-1 Central Oregon Bentonite 541-477-3351

Bentonite Pelbon American Colloid Co. 800-426-5564 847-392-4600

Bentonite Volclay American Colloid Co. 708-392-4600

Montmorillonite Stabilite Soil Stabilization Produces 800-523-9992

Enzymes Bio Cat 300-1 Soil Stabilization Products Co., Inc 800-523-9992

Enzymes EMCSQUARED Soil Stabilization Products Co., Inc 800-523-9992 Gillies et al. 1999, Watson

et al. 1996

Enzymes Perma-Zyme 11X The Charbon Group. Inc. 714-593-1034

Enzymes UBIX No. 0010 Enzymes Plus, Div of Anderson Affiliates 800-444-7741

Ionic Terrastone Morrhead Group 831-684-1148

Sulfonated Oils CBR Plus CBR Plus, Inc. (Canada) 604-684-8072

Sulfonated Oils Condor SS Earth Sciences Products Corp. 503-678-1216

Sulfonated Oils SA-44 System Dallas Roadway Products, Inc. 800-317-1968

Sulfonated Oils Settler Mantex 800-527-9919

Organic colloids

modified polysaccaride Dust Stop Cypher USA 615-365-4480 www.cypherltd.com

Frazer, Lance 2003 Ntl. Institute of Env Health Sciences

Clay Additives

Electro-chemical

Table 3.1 Dust Suppression Products

33

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Table 3.1 Dust Suppression Products

Lignosulfonate generic Sanders, et al 1997

Lignosulfonate CalBinder California-Fresno Oil Co. 209-486-0220

Lignosulfonate DC-22 Dallas Roadway Products, Inc. 800-317-1968

Lignosulfonate DC-9112 GE Water Technologies GE Betz Inc. 605-642-3147 866-439-8272 www,gewater.com

Lignosulfonate Dustac Georgia Pacific West, Inc. 360-733-4410

Lignosulfonate Dustac-100 Georgia Pacific West, Inc. 360-733-4410

Lignosulfonate Polybinder Jim Good Marketing 805-746-3783

Lignosulfonate RB Ultra Plus Roadbind America Inc. 888-488-4273

Molasses/Sugar Beet Dust Down Amalgamated Sugar Co. 208-733-4104

Tall Oil Emulsion Dust Control E Pacific Chemicals, Inc/ Lyman Dust Control

604-828-0218 800-952-6457

Tall Oil Emulsion Dustrol Ex Pacific Chemicals, Inc/ Lyman Dust Control

604-828-0218 800-952-6457

Tall Oil Emulsion Road Oyl ArrMaz Custom Chemicals, Inc. Winter Haven FL

Schommer & Sons Portland, Oregon 863-293-7884 www.roadproductscorp.com

Vegetable Oils Dust Control Agent SS Greeenland Corp. 888-682-6040

Vegetable Oils Soapstock Kansas Soybean Association Indiana Soybean Association

800-328-7390 800-735-0195

Organic Non-Petroleum

34

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Table 3.1 Dust Suppression Products

Asphalt Emulsion CSS-1 Any major asphalt supplier

Cutback MC-70 Any major asphalt supplierDust Oil/Dust Fluids Duo Prime Oil Lyondell Petrochemical 800-423-8434

Dust Oil/Dust Fluids EnviroKleen Midwest Industrial Supply, Inc. 800-321-0699 www.midwestind.com

Dust Oil/Dust Fluids Fuel Oil Pacific Northern Industrial Fuels 206-284-4421

Modified Asphalt Emulsion Asphotac Actin Inc. East Chicago, Ind 219-397-5020

Modified Asphalt Emulsion Coherex Witco Corp. Chandler AZ 800-494-8287 Gillies et al. 1999 Watson

et al. 1996Modified Asphalt Emulsion DOPE-30 Morgan Emultech, Inc. 530-241-1364

Modified Asphalt Emulsion

Penetrating Emulsion Primer (PEP)

Kock Asphalt Co 909-829-0505

Modified Asphalt Emulsion

Pennz Suppress-D American Refining Group EnVirotech Services

Inc Greeley, CO 814-368-1200 307-369-3878 www.pennzsuppress.com

Midwwest Research Instititute for the EPA, 1998

Modified Asphalt Emulsion Petro Tac Sytech Products Toledo OH 800-537-0288

Modified Asphalt Emulsion Road Pro Midwest Industrial Supply 800-321-0699

Modified Asphalt Emulsion Sandstill Energy Systems Associates 703-503-7873

Organic Petroleum

35

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Table 3.1 Dust Suppression Products

wetting additive aklyphenol ethoxylates

BASF Chemical Division, Mt. Olive, NJ 800-543-1740 www.basf.com Warhurst,Michael 1995

wetting additive Haul Road Dust Control Midwest Industrial Supply, Inc. Fairmont Supply Co

Green River, WY 307-875-2492 www.midwestind.com

wetting additive TerraBond Water Wetter

TerraBond Industries-Fluid Sciences, LLC 888-356-7847 www.terrabond.net D. Gebhart, et al. USAEC

Tech Report, 1996

wetting additive with both ionic and anionic properties

Chem-Loc 101 Golden West Industries Heber City, UT

Golden West Industries, Wright, Wyoming

800-321-dust

wetting additive with both ionic and anionic properties

Chem-Loc 102 Golden West Industries Heber City, UT

Golden West Industries, Wright, Wyoming

800-321-dust

wetting additive with both ionic and anionic properties

Chem-Loc 411 Golden West Industries Heber City, UT

Golden West Industries, Wright, Wyoming

800-321-dust

wetting additive, latex based sealant

DusTreat DC9136 GE Betz, GE Water Technology www.gewater.com

Surfactant

36

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Table 3.1 Dust Suppression Products

Acrylic co-polymer

Dust Buster - HR51 Midwest Industrial Supply Fairmont Supply Co

Green River WY 307-875-2492 www.midwestind.com

Acrylic co-polymer Envirotac II Environmental Products and

Applications, Inc. 888-674-9174 www.envirotac.com

Combination of Polymers Top Shield Base Seal Internationa, Inc. 800-729-6985

copolymer DustShield Soil-LOC, Inc, Scottsdale, AZ 888-828-7300 www.soil-shield.com

polymer emulsion DirtGlue DirtGlue Enterprises 888-606-6108 www.dirtglue.com

polymer emulsion Soiltac Soilworks, LLC Gilbert AZ 800-545-5420 www.soiltac.com

polymer emulsion TerraBond Dust Cap

TerraBond Industries-Fluid Sciences, LLC 888-356-7847 www.terrabond.net

Polyvinyl Acetate Aerospray 70A Cytec Industries 800-835-9844

Polyvinyl Acetate Soil Master WR Environmental Soil Systems, Inc. 800-368-4115

Vinyl Acrylic Earthbound L Earth Chem Inc. 970-223-4998

Vinyl Acrylic ECO-110 Chem-crete 972-234-8565

Vinyl Acrylic Liquid Dust Control Enviroseal Corp. 561-969-0400

Vinyl Acrylic Marloc Reclamare Corp.

Vinyl Acrylic PolyPavement PolyPavement Company 323-954-2240

Vinyl Acrylic Soil Seal Soil Stabilization 800-523-9992

Synthetic Polymer Emulsions

37

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Table 3.1 Dust Suppression Products

Vinyl Acrylic Soil Sement Midwest Industrial Supply, Inc. 800-321-0699

Gillies et al 1999, D. Gebhart, et al. USAEC Tech Report, 96 Watson et al. 1996

Vinyl Acrylic Soiloc-D Hercules Environmental 800-815-7668 770-303-0878

Vinyl Acrylic TerraBond PolySeal

TerraBond Industries-Fluid Sciences, LLC 888-356-7847 www.terrabond.net

Vinyl Acrylic Top Seal Soils Control International 817-526-5550 D. Gebhart, et al. USAEC Tech Report, 1996

polyacrylamides combined with super absorbents

Tri-PAM US Marine Corps 970-330-0281 908-464-1500

Vernon Prevatt, D. Hart (USMC brief)

38

Suppressant Type

Suppressant Category Product NAME Manufacturer or Primary

Distributor Regional Distributor Phone number Web site Citation/author

Table 3.1 Dust Suppression Products

blend of calcium chloride and magnesium chloride

Dust Fyghter Midwest Industrial Supply 800-321-0699 D. Gebhart, et al. USAEC Tech Report, 1996

calcium chloride Calcium Chloride liquid General Chemical 800-668-0433 www.gogenchem.com Sanders, et al 1997

calcium chloride generic Sanders, et al 1997

calcium chloride Dowflake Dow Chemical Oxford, Inc. Moyie Springs, ID 208-267-2297 www.dow.com

calcium chloride Liquidow Dow Chemical 800-447-4369

magnesium chloride Chlor-tex Soil-Tec 702-873-2023

magnesium chloride DustGard North American Salt Company Dust Busters, Evanston

, WY 307-789-3878 www.nasalt.com Sanders, et al 1998

magnesium chloride Dust-Off Cargill Salt 800-553-7879

magnesium chloride

magnesium chloride

Dust Busters, Evanston , WY 307-789-3878

Magnesium chloride (90%) and 10% surfactant (ethoxylated nonly phenol)

Dust Eliminator Brody Chemical Brody Chemical-Casper WY 800-488-2436 www.brodychemical.com

Magnesium chloride and proprietery corn based additive

Caliber DCA2000 Glacial Technologies

EnVirotech Services Inc Greeley, CO (multiple dust control products)

800-369-6878 www.envirotechservices.com Engle, David 2004. in Erosion Control

sodium chloride IMC Salt IMC Salt 800-323-1641

sodium chloride Morton Salt Morton International 312-807-2000

Water absorbing

39

TABLE 3.2 DUST SUPPRESSION APPLICATIONS GUIDE, is a product selection tool, compiled from published sources. This particular guide assembles products in general categories with the addition of application guidelines, environmental issues, application notes, limitations and attributes where known. The reader again should be cautioned that the table cannot be considered complete or comprehensive. It is probable that there are more substantial differences within a product category than is implied within the table. Since new products are continually being developed, the information compiled in Table 3.2 is incomplete from that perspective as well. Users are encouraged to work with vendors in testing new products….and just as importantly, in sharing the results. Detailed case studies with less proprietary data are needed.

40

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

Clay Additives Bentonite

unknown (but quality road construction is considered crucial to dust control)

generally unknown but no reported vegetation or freshwater impacts

1 to 3% of road material by dry weight

1 treatment every 5 years

may become slippery when wet if high fines occur.

agglomerates fine dust particles. Generally increases the dry strength of material under dry conditions

Electro-chemical Enzymes or Sulfonated Oils

low; 39% after one week and 0% after 11 months (Gillies et al.)

some products are highly acidic in their undiluted form. Needs product specific analysis

highly diluted at 1:600 in some cases but no application rate known

? Needs time to set up/cure

clay fines needed for best performance. Requires long curing time. limited life span Test on-site prior to large scale applications

changes characteristics of clay size particles. Generally effective regardless of climate conditions. Least likely to leach out.

Organic colloids modified polysaccharide biodegradable

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

41

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Dust Oil/Dust Fluids 85% initial

claimed non hazardous but with all petroleum based products there is the potential for hydrocarbon contamination.

.46 gal/sq ydMRI test cured for 45 hrs with no traffic

down time for curing was extensive

42

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Modified Asphalt Emulsion

95% after one week and 53% after 11 months (Gillies et al.)

can range from .1 to 1 gal per sq yd for initial app and less for reapps

blade mixing for stabilized roads and rolling

2

condition specific rolling required mechanically sprayed

not good in high pH soils in dry conditions may not retain resilience. Can be become crusty and fragment under traffic and wet weather. Some products are difficult to maintain Can be mixed with fresh or salt water. Waste oils contain toxic materials and must be processed to remove these toxins. Odorous. Sticky

binds or agglomerates surface particles because of asphalt adhesive properties. Some are film forming Waterproofs the road. Non toxic, non corrosive Effective in a multitude of environments Considered relatively expensive (Gephart).

Organic Petroleum

43

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Lignosulfonate 80% range

No strong water quality issues although BOD (Biochemical Oxygen Demand) may be high upon leaching into a small stream

.09 gal/sq yd initial followed by 3 maintenance doses of .045gal/sq yd annual

scarify to a depth of 4", prewet, mix insitu, compact

3 maintenance doses at a rate of .01 gal/ft2

No cure time suggested by at least one vendor. When prewetting the road the use of surfactant may be beneficial.

Product may stick to vehicles. On site mixing is costly. Effectiveness reduced by heavy rains. Becomes slippery when wet and brittle when dry. Difficult to maintain a hard surface. Less effective on igneous, crushed gravel and medium to low fines. Odorous.

Binds road surface particles. Under dry conditions it increases the dry strength of material. Retains effectiveness under long dry periods. Performs best in arid and semi-arid conditions. Can be reshaped in soils with high amounts of clay.

44

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Vegetable Oils

several products shown to have low impact on freshwater aquatic environments

.25 to .5 gal per sq yd initial

135 degree F heated application

1

the warmer the product the faster the penetration

cost of heated application trailers may be prohibitive, limited geographic availability oxidizes rapidly and then becomes brittle.

agglomerates the surface particles

Tall Oil Emulsion

claimed to be suitable for environmentally sensitive areas but mostly unknown

.3 to 1 gal per sq yd at 1:4 dilution rate 1

laid down like asphalt, mixed with crushed stone

several days of cure time suggested by at least one vendor. Difficult to maintain a hard surface. Effective in a wide range of aggregates

Adheres surface particles together. Greatly increases dry strength of material under dry conditions. Limited number of treatments needed.

Organic Non-petroleum

45

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Surfactant

wetting additive (some have ionic and anioinc properties) Also includes some latex based sealants

akylphenol ethoxylates have issues related to biodegradability and human impacts (9-10 mole nonyl phenol ethoxylates have been banned in Europe due to impacts on human endocrine system) also used to extinguish coal fires generally claimed non-hazardous

site specific and dependant on conditions

site prep is more dependant on primary suppression agent and not surfactant

Diluted at rates of 1:1000 or less and then applied either with primary suppressant or with water only makes water wetter

46

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Acrylic co-polymer

80% after 12 mo and 95% after 8 for vinyl acrylic (one result) 95% after one week and 85% after 11 months (Gillies et al.)

claimed non hazardous site specific

scarifying and grading and mixed insitu and compacted followed by topical application for extreme protection the product needs to be mixed insitu

at least 30% solids, addition of surfactant may enhance penetration

do not store or apply below freezing do not apply during or when rain is expected in 24 hrs test bed cured for 7 days

polyacrylamidces combination with super absorbents

reduced dust by 80-90% at helicopter landing sites in the desert

none listed 1 lb for every 150 ft.

product is applied with a fertilizer spreader then raked and saturated with water at a rate of 1 gallon per 5 sq/ft. Then topped with an emulsion

application varies depending on soil pH

not commercially available

47

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

polymer emulsion

environmentally safe and biodegradable no known water quality or plant impacts but needs product specific analysis

1 gal undiluted per 50 sq ft

May require specialized equipment for mixing in with soil if not applied topically

can apply either sprayed topically or mixed in place, followed by compaction

difficult to maintain a hard surface

binds surface particles because of glue like properties

Synthetic Polymer Emulsions

48

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Vinyl Acrylic80% on average after 12 months 95% after 8 months

environmentally safe

.5 gal/sq yd most typical one product suggests .75 gal/ sq yd (1st coat) followed by 1:15 at .5gal/sq yd

Scarification recommended as the product runs easily grade, scarify, apply 1st coat, roll, apply 2nd application and roll again grade top 3-6 inches of soil. Best when applied to a moist surface and optimal soil moisture at least one product does not recommend pre-wetting

varies: one vendor suggests road use can be resumed soon after application, other vendors suggest product needs to cure for 8-12 hrs at 72 deg F. Two step application followed by compaction suggested for all soil types

curing/drying time is typically recommended do not apply below 36-40 deg F. Not recommended for highly trafficed surfaces

binds soil particles together may include a dye so applicators can better ascertain coverage Generally considered non-toxic. Best on lightly trafficed surfaces

49

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

calcium chloride less than MgCl2

long term may use result in water quality degradation in runoff conditions Freshwater aquatics species may develop chloride concentrations; negligible if proper buffer zones exist. Similar impacts on trees as Mag Chloride.

.4 gal/sq yd or

can be topically sprayed or mixed in place (requires scarifying)

4-Feb

works better in winter than some other products

corrosive to metal (corrosive inhibitors can be added) It requires a minimum RH level to absorb moisture from the air. Does not perform as well as MgCl2

over long, dry spells. Rainwater tends to leach out soluble chlorides. Slippery when wet if a high amount of fines are present.

At 77o F, It starts to absorb water at 29% RH. At 100o F, it starts to absorb water at 20% RH. Lower freezing point than MgCl2. Treated roads can be regraded and recompacted with less impact on product capability Performs better than MgCl2 in high humidity. Moderately priced. Lowers the freezing point of the road moisture and helps prevent frost heaving, thus reducing road maintenance. Provides greater density with less compaction effort

50

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

calcium chloride (flake)

More deliquescence than MgCl2, up to 98% for 1-5 days

All chlorides pose a potential hazard to offsite plants after a heavy rainfall. same as liquid CaCl2.

1.5% by weight of aggregate

tightly blade and pre-wet

works well on steep slopes no 2nd application needed grading only

Water absorbing

51

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

magnesium chloride generally high

corrosive, water shed quality issues can be minimized with adequate buffer zone. Affects pine, hemlock, poplar, ash, spruce and maple. Potential concerns with spills. (surfactant additive (particularly nonyl phenol ethoxlates) and/or other proprietary additives may also have impacts)

.5 gal/sq yd initial maintenance is .3 gal/sq yd (some mines using very diluted ratios (1%) instead of surfactants with normal watering recommended application rates vary by road type with gravel the lowest per sq yd and clay the highest

2-3 full treatments per season

varying combinations used (e.g. different surfactants or additives; including similar ratios of CaCl2 and MgCl2. Several mines switch to CaCl2 in Winter

corrosive to metal may have limited effectiveness on coal fines Requires addition of water, especially if below 32% relative humidity. Rainwater and over-watering tend to leach out soluble chlorides necessitating reapplication. If roads contain a high fine content, they may become slippery when wet.

Absorbs water from the air at 32% RH independent of temperature. Harder surface than CaCl2. Treated roads can be regraded and recompacted with less impact on product capability Effective in drier climates. Reasonable cost. Less maintenance needed (Sanders). Generally provides the best combination of application ease, durability, cost and dust control for semi-arid, semi-humid and humid climates (Gephart et al.)

52

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

Water water

Low (40%) at typical rate. When rate of use is doubled, effectiveness may increase to 90% for short durations, sometimes as low as 12 minutes EPA, AP-42 (1998) notes that moisture ratio of 2 equates to 75% efficiency. Significant increases in moisture ratio are needed to increase efficiency to 95% (e.g. 2.5 times)

increases siltation requires large quantities

light watering preferred and numerous applications

blading and repeated reapplications as needed site specific

evaporation necessitates numerous reapplications controls dust for a limited time, (as low as 12 minutes in high temp and wind conditions). labor intensive. Expensive over long term use when all costs are considered. Can pump fines to the surface

agglomerates the surface particles and is normally readily available. Can have positive immediate results and is generally considered inexpensive as a short term dust control

53

Suppressant Type

Suppressant Category

PM 10

effectiveness The author cannot verify that all levels listed are time averaged; the method preferred by MRI for its ability to show true effectiveness.

Environmental Impact

Recommended application rate (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site preparation and or maintenance needed

# of applications per year (general vendor recommendations - documentation of effectiveness on haul roads is often inadequate)

Site specific notes Limitations Attributes

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS GUIDE

The reader is referred to the following sources for additional selection guides:Ferguson, John, W. Downs, D. Pfost. 1999. Fugitive Dust: NonPoint Sources, Agriculture MU Guide, U of MO

Bolander, Peter, and A. Yamada. 1999. Dust Palliative Selection and Application Guide. USFS Sanders, Thomas, and J. Addo. 1993. Effectiveness and Environmental Impact of Road Dust Suppressants, Mountain Plains Consortium

Gebhart, Dick, M. Denight, and R. Grau. 1999. Dust Control Guidance and Technology Selection Key, US Army Construction Engineering Research Lab.

Specific test results (effectiveness) for dust suppressants can also be found in the following sources:EPA. 1998. Compilation Air Pollutant Emission Factors, AP-42, Volume I, Fifth Edl, Section 13.2.2, Unpaved Roads. Research Triangle Park, NCCowherd.C. Jr. et al., 1988. Control of Open Fugitive Dust Sources, EPA-450/3-88-008, US.EPA, Research Triangle Park, NCMuleski, G. E., et al., 1984. Extended Eval' of Unpaved Road Dust Suppressants in the Iron and Steel Industry, EPA-600/2-84-027, EPA, OHCowherd.C. Jr. and J. S. Kinnsey. 1986. Indentification, Assessment and Control of Fugitive Dust Particulate Emissions, EPA-600/8-86-023, EPA, OHMuleski, G.E. and C. Cowherd, Jr., 1986. Evaluation of the Effectiveness of Chemical Dust Suppressants on Unpaved Roads, EPA-600/2-87-102, EPA, OHGillies, et al. 1999. Long Term Efficiencies of Dust Suppression to Reduce PM 10 Emissions From Unpaved Roads , JAWMA, 49, 3-16

The above list and all other materials supplied throughout this document are intended to provide a convenient source of information for the reader, so as to serve as a starting point for a discussion of various features and applications.....but the data is not necessarily fully comprehensive or complete. It is the user's responsibility to thoroughly research and compare products and vendors to determine which can provide high quality results and services. Vendors are not necessarily equally reliable, or comparable relative to timeliness, price and their adherence to recommended application procedures. It is not the intent of this document to endorse any product or vendor and any that have been referenced were cited because of their willingness to provide information only.

Thompson, R.J. and A. T. Visser 2002. Benchmarking and management of fugitive dust emissions from surface mine haul roads. Table 1 Palliative Selection Matrix

BOD Biochemical Oxygen Demand is a measure of the amount of biodegradeable organic material present in a sample of water. 5mg/L or less is desireable.

54

TABLE 3.3 DUST SUPPRESSION ON MINE HAUL ROADS - COST WORKSHEET, is a price and product comparison worksheet. Users can explore various costing scenarios with the excel spreadsheet, but should be cautioned that all data included involves estimates. Reliable pricing data are very difficult to obtain. First of all, there are a multitude of variables affecting price, and as many affecting the selection of a given product and application. Secondly, we were not able to ascertain the price of all dust suppressants that are currently being used in Wyoming coal mines. When the price of a product has been provided by a vendor or end user and is felt to be reasonably accurate it was included. However, costs of product and application measures vary significantly by location and situation.

Down time for example is a substantial cost that undoubtedly prohibits the use of certain suppressants but is difficult to measure. Actual costs per mine need to be calculated and used instead. Down time estimates for delays on a main railway line for coal trains was $1 million per hour (UP: Oct 2, 1998, Perkins, Wyoming).

The cost and amount of road maintenance needed, such as grading, and compacting are also estimates, ascertained from the 2004 USFS Cost Estimating Guide for Road Construction. The USFS estimates were doubled for use on wider haul roads. The frequency of the maintenance required for various suppressant types is generally unknown, and is always situationally dependant. The figures provided are adjustments made to data supplied by Sanders, 1997. The suppressant tested with the lowest aggregate loss was lignosulfonate. The difference in aggregate loss compared to lignosulfonate was calculated as a percentage and this adjustment ratio used to estimate the need for road maintenance. CaCl2 for example was estimated to need 148% more blading and related road maintenance than lignosulfonate based on Sanders’ findings of 148% more aggregate loss. The worksheet is intended to help the user recognize some of the costs beyond initial application. Other costs that may have been overlooked for a given site or product and can be added by users. Users are referred to the USFS publication, Bolander et al.(1999) Dust Palliative Selection and Application Guide (pp.13-14) for additional costing worksheets. It is apparent that more detailed records are needed in order to better ascertain the cost effectiveness of a given product or application method. Application rates for example are an important factor in product effectiveness, as is the frequency of repeat applications, yet most of the information supplied by vendors is in ranges so wide as to be unusable. Similarly, more detailed reporting of water usage would assist in the determination of water’s effectiveness and cost.

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1

2

3

4

56

789

10111213141516171819

2021

A B C D E F G H I

Suppressant Type water synthetic polymer

electro chemical

Suppressant category water CaCl2 flake CaCl2 MgCl2Ligno- sulfonate (Lignin)

Modified Asphalt Emulsion

Acrylic co polymers vinyl acrylics

Enzymes Ionics Sulfonated oils

Product Examples many examples have proprietary ingredients and varying application recommendations that may enhance peformance beyond general category product (mi = mile, Lignin'=Lignosulfonate, agg' = aggregate, $0=intential illustration of no data)

Water

DustGard DustFyghter DustOff Brody Chem Caliber DCA 2000, etc

PennzSuppress Road Oyl, Coherex

Soil Sement Dust Shield Dirt Glue DB- HR51

Terrastone BioCat EMC2

Cost per undiluted unit (gal, ton,etc.) .02/gal (in place) USFS

0.30/gal (Sanders)

$ 284/ton (vendor)

.30/gal (Sanders)

.90-1.30/gal avg (vendor)

Dilution rate na 1:2 na 1:2 1:1 1:4

application rate of diluted mixture 10000 gal/mile (Vendor)

.4gal/sq yd (USFS)

1.9lb/sq yd (USFS) .5gal/sq yd

.085gal/sq yd x 2 apps reapps at .045 sq yd

.5gal/sq yd

amount of undiluted product/mile (gal, or lbs) 9293 133760 11616 11968 7040Product cost per sq yd $0.0396 $0.2700 $0.0495 $0.3000Water portion of mixture in gal/mi 10000 18867 0 23,584 $11,968 28160initial app Product cost per mile $2,788 $19,008 $3,485 $21,120initial app pre wetting/mi (USFS 2004, vendor) 10,000 gal/mi $200 $200 $200 $200initial app water portion of mixture (gal x .02/gal) USFS $200 $377 $0 $472 $239 $563 $0 $0surfactant (wetting additive) $85/10000gal $85 $160 $0 $200 $102 $239 $0 $0initial app scarification/mi (USFS,2004) 1730/mi $1,700initial app blading/mi (USFS,2004) 680/mi $680 $680 $680 $680initial appl mix in place (USFS,2004)(blade rate x 2) 1760/mi $1,760initial app rolling/compacting (if separate event) 860/mi $860initial app miscellaneous costs (detours)

initial app curing (down time cost per mile) acrylics and polymers expected to be significantly higher due to projected curing time recommended by vendors, but actual value is uknown.

INITIAL APPLICATION SUBTOTAL (sum of rows 11-20) $1,165 $4,206 $19,688 $5,037 $25,981 $803 $0 $0

water absorbing organic petroleum

Table 3.3 DUST SUPPRESSION ON MINE HAUL ROADS - COST WORKSHEET

57

1

2

3

A B C D E F G H I

Suppressant Type water synthetic polymer

electro chemical

Suppressant category water CaCl2 flake CaCl2 MgCl2Ligno- sulfonate (Lignin)

Modified Asphalt Emulsion

Acrylic co polymers vinyl acrylics

Enzymes Ionics Sulfonated oils

water absorbing organic petroleum

Table 3.3 DUST SUPPRESSION ON MINE HAUL ROADS - COST WORKSHEET

222324252627

28

29

30

31

32333435

36

1st reapplication (50% initial product rate but full cost of app) USDA and product vendors $2,812 $10,184 $3,295 $15,421 $803 $0 $0

2nd reapplication (repeat of 1st reapplication) $2,812 $3,295 $15,421 $803 $0 $03rd reapplication (see North Carolina Div of Air Q) $2,8124th reapplication5th reapplication6th reapplication

Annual Maintenance blading (USFS,2004) $680/mi x 52 weeks/yr (cost shown is once/wk/mi for Lignin rated lowest in agg' loss by Sanders, 1997 (Others adjusted by maintenance ratio:row 32)

$70,720 $52,374 $35,360 $36,359 $35,360

Water estimate based on one mine's use of 81.76 mil gallons per year(haul road length of 5 miles, 75% of water use on roads) Maintenance water (@ .5 gal/sq yd/day)would equal 12848000 gal Water for Lignin' rate of .13gal/sq yd/day is based on vendor recommendation. Water only double rate based on NC Div of Air Quality. Thompson and Visser 2002 and Rosbury and Zimmer 83 , and USDA FS suggest watering intervals of 30 min during peak season which is 8 months per year. Winter interval: every 3 hrs. (.082 per pass x 6 average passes)

24528000 12264000 12264000 12264000 3188640

Maintenance water cost/mile annually (USFS) Uses Row 29 estimated water use levels x $200/10000gal $490,560 $245,280 $245,280 $245,280 $63,773

Maintenance aggregate replacement (Sanders 1997. Modified for haul trucks, 120' haul road and aggregate cost in place of $11.57/ton) $1,831,610 $1,356,458 $915,805 $941,680 $915,805

Adjustments (Sanders, 1997) used difference in aggregate loss to justify additional maintenance (water only adjustment based on NC Div of Air Q, Thompson and Visser and Rosbury and Zimmer). Flake CaCl2

based on mine engineer performance evaluation

200.00% 148.12% 100.00% 102.83% 100.00%

Intangibles $0 $0 $0 $0 $0 $0 $0surfactant $85/10000gal of water (if used) $208,488 $104,244 $27,103 $0 $0 $0suppressant at 1% solution 100gal/10000gal tanker ($30) $36,792 $36,792

TOTAL annual cost per mile application and maintenance $2,602,543 $1,703,544 $1,330,561 $1,271,737 $1,098,865 $2,408 $0 $0

58

1

2

3

A B C D E F G H I

Suppressant Type water synthetic polymer

electro chemical

Suppressant category water CaCl2 flake CaCl2 MgCl2Ligno- sulfonate (Lignin)

Modified Asphalt Emulsion

Acrylic co polymers vinyl acrylics

Enzymes Ionics Sulfonated oils

water absorbing organic petroleum

Table 3.3 DUST SUPPRESSION ON MINE HAUL ROADS - COST WORKSHEET

3738394041

4243444546

Sources:USFS Cost Estimating Guide for Road Construction 2004USDA FS Dust Palliative Selection and Application GuideSanders, Thomas et al. 1997. Relative Effectiveness of Road Dust SuppressantsAverage haul truck = 550,000lbs(equal to 100 vehicles) 216 haul trucks per day (9x24) X 3.6 to adjust for 120' road. Aggregate replacement $11.57/ton for crushed rock in place (adjust for scoria as known)Thompson, R.J and A.T.Visser. 2002. Benchmarking and management of fugitive dust emissions from surface mine haul roads.Rosbury, K.D., and R. A. Zimmer. 1983. Cost Effectiveness of Dust Controls Used on Unpaved Haul Roads, PEDCO Environmental, Inc., US Bureau of MinesNorth Carolina Dept of Env and Nat Resources Div of Air Quality. 2003. Economic Analysis of Particulates from Fugitive Dust Emissions Sourcesvendors (product vendors and specific mine information (anon')

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APPENDICES

61

62

Appendix A:

Dust Suppression Survey and Results

63

64

Dust Suppression Survey (Results)

The following inquiry will assist the researcher in compiling a recommendation of “best practices” for dust abatement on mine haul roads. Although the results will be

tabulated, your name or company will not be associated with your response. 1. Please indicate your primary chemical dust suppressant MgCl2 (3), CaCl2 (1), PennzSuppress (1) 2. Please use the following criteria to explain why you use the Primary product you selected in Q1. Check all that apply and add any other reasons that are not listed.

_5__ can be applied with no down time for haul trucks _4 _ is readily available locally _2__ is one of a limited list of available products offered by our area vendors _4__ appears to be more cost effective than other options _4__ appears to be environmentally safe

_4__ can be applied with standard equipment (water trucks) by our employees _3__ in addition to suppressing dust, the product seems to improve or maintain

the road surface drivability and/or slows breakdown and need for grading _2__ requires minimal staff training to adequately apply _1__ (your criteria)_Vender maintains automated system_________________

___ (your criteria)_______________________________________________ ___ (your criteria)_______________________________________________

4. Do you currently use a surfactant to improve the efficiency of the water and/or your primary suppressant? _1__yes __4_no If yes _ChemLoc 102 (1)____ (product)

5. A few mines no longer use a surfactant but use a very diluted application of their

primary suppressant instead. Please comment on your mine’s use of either a surfactant or a very diluted product with general watering:

-1000gal. of MgCl2/45,000gal. water, 3 loads every 2 or 3 days -Surfactant used in each truck load -We use diluted product on haul roads that we grade a lot -Stronger on outlying roads -Intend to use diluted MgCl2 with general watering in the future 6. Would you recommend your primary product (by cost and performance) to be

used by other mines for haul road dust suppression? Explain: -MgCl2- Yes, low cost -MgCl2- Yes, when properly applied, and minimal blading afterwards product provides effective low cost suppression compared to alternatives -CaCl2- Cost effective with good results -PennzSuppress- Depends on the mine, cost is prohibitive. However, the dealer support and maintenance is critical to our operation. -MgCl2- Cheapest available product that meets the DEQ/AQD requirements.

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7. What, in your opinion is the biggest problem or limitation in using your primary product for haul road dust suppression now and in the future?

-No problem with MgCl2. Issue is maintenance and upkeep of haul roads. - Product (CaCl2) is brought in by railroad into Gillette. Railroad does not put a priority on locating RR cars so vendor can off-load product. Sometimes, the RR cars w/product sit in the yard for a week before the vendor can access them. - MgCl2- Educating the workforce that unnecessary grading of the road rapidly reduces the effectiveness of the treatments. Secondary concern is availability of the product as more industries move to use it in the face of continuing drought. - Spillage from haul trucks covers the chemical and makes it inefficient -PennzSuppress- Cost 8. Have you tried other road dust suppression products that you were unsatisfied

with? Which ones and why? - Tried emulsified tree resin, stuck to vehicle parts causing paint to chip. - EMC2 did not work at all -Unichem 9. If you have discontinued the use of a product which performed well please

explain here: - MgCl2, expensive to have shipped to the mine. Not simple or automated for us to use. Contractors don’t want to use their tanks because of fear of corrosive behavior.

10. Please rank the following in the order that presents the biggest challenges to dust suppression at your coal mine. (1 being the highest, 5 being the lowest (rank only 5 of 6)). To determine rank, average scores were calculated. Items ranked #1 = 5 points, #2 = 4 points, #3 = 3 points, #4 = 2 points, #5 = 1 point, unranked = 0 points.

Rank __3.8____ (1) Cost of suppressants __2.8__ (2) Monitoring Data (to show effectiveness of suppressant and when

reapplication is necessary) __2.4____ (3) Employee training __2____ (4) Proper Application _ 2____ (4) Other (describe) Rail delivery issues; Spillage 1.8___ (5) Need for a better product Summary: Five surveys were returned. The majority of respondents reported using MgCl2. In the ranking of challenges Other issues were selected twice, and in both instances the issue was ranked of highest importance for that mine. Overall the Other category ranked tied for fourth.

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Appendix B:

Dust Control Plan and Self Inspection Checklists

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68

Air Quality of Idaho: Supplemental Fugitive Dust Control Information

________________________________________________________________________ Developing a Dust Prevention and Control Plan Keeping potential fugitive dust problems under control is an everyday job. Plan ahead by developing a dust prevention and control plan as follows: 1. Identify all potential fugitive dust emission sources.

• Start with a facility site plan map.

Record all paved haul roads, unpaved haul roads, stockpiles, material transfer points, material conveyances, parking lots, staging areas, and other open areas subject to wind erosion. Indicate prevailing wind direction on your map.

• Study daily traffic volumes Determine whether roads and open areas are used frequently or occasionally. Consider daily routine modifications that will reduce traffic in some areas or eliminate it altogether 2. Assign dust control methods.

Determine the appropriate dust control method for each sources identified from your facility. If desired, color –code your map to indicate which dust control method to apply where.

3. Determine frequency pf application.

For each source and each control method identified, determine how frequently dust control treatments should be applied. Develop a Self-Inspection Checklist to record the scheduled applications. (See below).

4. Record all dust control activities.

It is a good practice to record your dust control activities on your checklist, along with the daily weather information, such as average wind speed and direction, temperature, rainfall, etc. Recording the information will enable you to monitor and evaluate the success of your efforts.

5. Monitor your dust control efforts.

You will need to monitor your dust control activities on a regular basis to ensure that the measures taken are adequately controlling fugitive dust.

69

Self-Inspection Checklist Use a self-inspection checklist to help incorporate the routine tasks of fugitive dust control into your daily schedule. The checklist serves as a job reminder on a daily basis and as a record of your efforts to keep dust problems to a minimum. You can identify problem areas before they get out of hand, and anticipate adjustments for seasonal changes or unforeseen circumstances. The sample checklists on the following pages can be used to document dust control methods as well as weather conditions. It is recommended that you use a checklist for each source of fugitive dust emissions. Example Dust Control Plan Fugitive Dust Sources: Unpaved Haul Roads Control Method: Chemical Dust Suppressant Frequency of Application: Every three months or as needed Record - Keeping: Date suppressant applied and area covered Monitoring of Control Efforts Roads monitored daily Special Considerations: • Traffic limited on haul roads by

placing product near the entrance of facility

• Speed limit of 10 miles per hour on facility grounds

70

Example Self-Inspection Checklist: Fugitive Dust Control Method Log Fugitive Dust Source: Unpaved Haul Roads Date Time Control Method Comments 4-1-02 7 am Magnesium Chloride

applied All haul roads on facility grounds

6-1-02 7 am Magnesium Chloride applied

Entrance of facility/stock pile area only

8-1-02 7 am Magnesium Chloride applied

All haul roads on facility grounds

10-1-02 - See weather log 12-1-02 - See weather log

Self-Inspection Checklist: Weather LogDate Temperature Wind Speed/

Direction Amt. of Rainfall Comments

10-2-02 55 F (high) 5 mph 0.10 inch Wet, cloudy, cold

10-8-02 50 F (high) 8 mph 0.0 inch Wet, cloudy, cold

10-15-02 56 F (high) 8 mph 0.05 inch Wet, cloudy, cold

10-22-02 52 F (high) 7 mph 0.0 inch Wet, cloudy, cold

Best Management Practices: Fugitive Dust Control Methods To control fugitive dust emissions, the Idaho Department of Environment Quality (DEQ) and representatives of the rock crushing industry have developed Best Management Practices (BMPs) for the following fugitive dust generating sources:

Paved public roads Unpaved haul roads Conveyor transfer points and screening operations Crushers and grinding mills Stockpiles

Although directed at the rock crushing industry in particular, many of these practices are applicable to mining and mineral processing facilities, sand and gravel operations, and concrete asphalts batch plants as well. The recommendations specific to haul roads follow:

71

Unpaved Haul Roads Fugitive dust control methods for unpaved haul roads include:

• Limit vehicle traffic on unpaved haul roads; • Limit vehicle speeds on unpaved haul roads. If a speed limit is imposed, post

signs along the haul road route, clearly indicating the speed limit. Place signs so they are visible to vehicles entering and leaving the sites of operations.

• Apply water to the surface of the unpaved road. Control runoff so it odes not saturate the surface of the unpaved haul road and cause trackout. If runoff is not or cannot be controlled, try applying gravel to the surface of the unpaved haul road over an area sufficient to control trackout

• Improve aggregate on the surface of the unpaved haul road; and • Apply an environmentally safe chemical dust suppressant to the surface of the

unpaved haul road.

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Appendix C:

Dust Palliative Selection Matrix (Thompson and Visser)

73

74

The following chart by Thompson and Visser (2002) provides additional comparisons on the perceived performance of several dust palliatives relative to plasticity, slope, traffic volumes and applications. (“Benchmarking of Fugitive Dust Emissions from Surface-Mine Haul Roads” p. A29.)

75

76

Appendix D:

Dust Palliative Selection Matrix (Bolander and Yamada, USFS)

77

78

The Product Selection Chart prepared by Peter Bolander and Alan Yamada for U.S. Forest Service’s Technology and Development Program is published in “Dust Palliative Selection and Application Guide” and can be found online at http://www.wsdot. wa.gov/TA/T2Center/DustGuide.pdf. This table offers information for dust suppression selection based on use/traffic volumes, surface material, and climatic conditions.

Notes: (1) May require higher or more frequent application rates, especially with high truck volumes (2) Greater than 20 days with less than 40% relative humidity (3) May become slippery in wet weather (4) May leach out in heavy rain (5) SS-1 or CSS-1 with only clean, open-graded aggregate (6) Road mix for best results

(Bolander, Yamada p.12 1999)

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Appendix E:

Dust Suppression Bibliography (T. Stevenson, 2004)

81

82

Primary Author Authors Title Year Name of Journal or Publication Name of Publisher URL

Arizona Dept of Environmental Quality

Arizona Department of Environmental Quality Air quality exceptional and natural events policy PM10 best available control measures

2001

Associated Press International EPA Watching Dust From Mines, Roads 2003 Associated Press State and

Local Wire Associated Press

Australia Dept of the Environment and Heritage

Dust Control, Best Practices Environmental Management in Mining, Australia 98 Sustainable Industry;

Sustainable Minerals

Australia Government; Department of the Environment and Heritage

www.deh.gov.au/industry/industry-performance/minerals/booklets/dust/dust1.html

Axetell, Ken, Jr. Survey of Fugitive Dust from Coal Mines 78 EPA 68014489 EPA

Banard, W.R. Stensland, G.J; Gatz, D.F.

Development of Emission Factors for Unpaved Roads: Implications of the New PM10 regulations. Transactions, PM10

Implementation of Standards

88 Air Pollution Control Association

Barnard, W. Improved fugitive dust PM10 emissions estimates for trends

92Transactions, Standards and Non-Traditional Particulate Source Controls

Air and Waste Management Association

Barnard, W.R. Development of emission factors for unpaved roads 88

Transactions, PM10

Implementation StandardsAir Pollution Control Association

Baxter, Roberta Arrest that Fugitive Dust! 2003 Erosion Control Forester.net http://www.forester.net/ecm_0203_arrest.html

Becker, D.C.Quantifying the Environmental Impact of Particulate Deposition from Dry Unpaved Roadways

unpublished Master's thesis Iowa State University

Beggs, T. W. User's Guide: Fugitive Dust Control Demonstration Studies 85 EPA EPA

Berthelot, C. Carpentier, A.Gravel Loss characterization and Innovative Preservation Treatments of Gravel Roads: Saskatchewan, Canada

2003 Transportation Research Record

National Research Council

Blackwood, T. R. Assessment of Road Carpet for Control of Fugitive Emissions from Unpaved Roads 79 EPA EPA

Blanc, T.R. Lingosulfonate StabilizationProceedings - ARTBA-NACE Conference Local Transportation

83

Primary Author Authors Title Year Name of Journal or Publication Name of Publisher URL

Bolander, P. Chitwood, L.; Steele, H.M.;

Lessons learned from the failure of a bituminous surface treatment in central Oregon

Transportation Research Record

National Research Council

Bolander, P., Yamada, A.

Dust Palliative Selection and Application Guide 99 Forest Service Technology

and Development Program

San Dimas Technology and Development Center

Bolander, PeterA Guideline to Liquid Spray Applications for Erosion Contol, Dust Abatement, and Tackifiers

96 U.S. Forest Service

Bolander, Peter Chemical Additives for Dust Control - What We've Used and What We've Learned 96 USDA Forest Service,

Portland Oregan

Carnes, D. H. The control of fugitive emissions using windscreens 82

Third Symposium on the Transfer and Utilization of Particulate Control Technology, Vol IV.

USEPA

Carter, R.Cut costs by controlling dust; heavy haul-road dust can stir up haulage and maintenance problems

96 Coal Age, vol 104, n 12

Champlin, Robert L.

Control of Fugitive Dust from mining haul roads 78 EPA

University of Wyoming, Institute of Energy and Environment

Colbert, W.Center for dirt and gravel road studies

Natural Systems Approach to preventing environmental harm from unpaved roads 2003 Transportation Research

Record, v 1, n 1819National Research Council

Council of Fresno County Government

Overview of Regional Transportation Planning Agency Process to Identify and Implement Best Available Control Measures in Support of the PM10 Plan for the San Joaquin Valley

2002 http://www.fresnocog.org/aq-modeling/bacm/bacm.htm

Countess, Richard

Methodology for Estimating Fugitive Windblown and Mechanically Resuspended Road Dust Emissions Applicable for Regional Scale Air Quality Monitoring

2001Western Governor's Association Contract 30203-9

Western Governor's Association

Cowherd, C Cost Effectiveness of road dust controls 82 EPA Report EPA

84

Primary Author Authors Title Year Name of Journal or Publication Name of Publisher URL

Cowherd, C Kinsey, J.S. Identification, Assessment and Control of fugitive dust particulate emissions 86 EPA Report EPA

Cowherd, C. et al. Development of Emissions Factors for Fugitive Dust Sources 74 EPA

Cowherd, C. Guenther, C.M.Development of Methodology and emission inventory for fugitive dust for the regional air pollution study.

76 EPA Office of Air Quality Planning and Standards

Cowherd, C. Kuyhendal, W.B. Fine Particle Components of PM10 From Fugitive Dust Sources

97Air & Waste Management Assoc. 1997 Proceeding

Cowherd, C. Fugitive Dust Emissions 96 MRI

Cowherd, C.

Profiling Data for open fugitive dust sources Prepared for US EPA, Emission Factors and Inventory Group, Office of Air Quality Planning and Standards

99 EPA, MRI

CTIC Road Dust Suppressants 89Colorado Transportation Information Center, Bulletin #3

Dept. of Civil Engineering, Colorado State Universtiy

Cuscino, Thomas Fugitive Dust from Vehicles Traveling on unpaved roads 76 EPA EPA

Dubyk, S. Fugitive Dust Control Techniques and Businesses 2004 website

New Mexico Dept of Environmental Air Quality Bureau

www.nmenv.state.nm.us/aqb/dust_control.html

Dulla, R.G. Withycombe, E Particulate control measure feasibility STUDY 97 Maricopa Association of

Governments Report Sierra Research

Dunkins, R. Fugitive Dust Background Document and Technical Information Document for Best Available Control Measures

92 EPA

Dyck, R.I Strukel, J.J. Fugitive Dust Emissions From Trucks on Unpaved Roads 76 Environ. Sci. Technol. 10,

1046-1048

Eaton, R.A; Gerard, S; Gate, D.W. Rating Unsurfaced Roads 88 Army Corps of Engr.

Engle, David Road Maintenance Techniques and Products Have Made Great Strides 2004 Forester Communications

January/Feburary Forester.net

Englehart, P.J. Muleski, G.E.Open fugitive dust PM10 control strategies study

80 Study Midwest Research Institute

EPA EC/R Inc. NC Control Techniques for Particulate Emissions from Stationary Sources, Vol 1 EPA 450381005a EPA

85

Primary Author Authors Title Year Name of Journal or Publication Name of Publisher URL

EPA EC/R Inc. NC Control Techniques for Particulate Emissions from Stationary Sources, Vol 2 EPA 450381005b EPA

EPA40 CFR Part 52: SIPs for Lead Nonattainment - IIB: Reasonable Available Control Measures (draft)

92 EPA EPA

EPAWestern Regional Air Partnership

40 CFR Part 5: Regional Haze Regulations Vol. 64, No. 126, July 1999 Federal Register EPA www.wrapair.org/309/index.html

EPAMidwest Research Institute

Compilation of Air Pollution Emissions Factors Volume 1, AP-42, Chapter 13 Unpaved Roads

EPA Emission Factor and Inventory Group

http://www.epa.gov/ttn/chief/ap42/ch13

EPAMidwest Research Institute

Emission Factor Domumentation for AP-42 Section 13.2.2 Unpaved Roads 1998 EPA final report

EPA Wyo Dept of EQUSEPA Region 8 - State Implementation Plan - Wyoming - Section 14 - Control of Particulate Emissions

98 Wyoming Dept of Environmental Quality

https://yosemite.epa.gov/R8/R8Sips.nsf/Wyoming?OpenView

EPA Emission Control Technologies and emission factors for unpaved road fugitive emissions 87 EPA EPA (The Center)

EPAMidwest Research Institute

Emission Factor Documentation for AP-42 Section 13.2.2 Unpaved Roads 1998 EPA final report EPA

EPAEPA's Interpretation of the HSWA prohibition on the use of hazardous waste as a dust suppressant

85 EPA EPA

EPA National Air pollutant emission trends, procedures 2000 EPA EPA

EPA Review of Surface Coal Mining Emission Factors EPA http://www.epa.gov/ttn/chief/ap42

/ch11/final/c11s09.pdf

Epps, A. Eshan, M. Laboratory Study of Dust Palliative Effectiveness 2002 Journal of Materials in Civil

EngineeringFerguson, John H. Fugitive Dust:Nonpoint Sources MU Ag Guide Univeristy of Missouri

Extension

Fitz, D. R. Moon, K. C, and Zeldin, M.

Evaluation of fugitive dust control methods in the Coachella Valley 93 Proceedings Air and Waste

Management Association

Air and Waste Management Association

86

Primary Author Authors Title Year Name of Journal or Publication Name of Publisher URL

Fitz, D. R. Evaluation of Watering to control dust in high winds 2000 JAWMA

Fitz, D. R. Field Study to Determine limits of best available control methods for fugitive dust under high wind conditions.

96 CE-CERT Document University of California

Fitz, D.R Bumiller, K Evaluation of Watering to Control Dust in High Winds 2000 JAWMA 50, 570-577

Frazer, Lance Down with Road Dust (innovations) Dust Stop 2003 Environmental Health

Perspectives

National Institute on Environmental Health Sciences

Freeston, Frank J.

Runoff of oils from rural roads treated to suppress dust 72 EPA EPA

Fu, L. Leung, D.Y.C. Analysis on Emission Factor of Fugitive Dust from Road Traffic 97 J. Environmental Science 9,

501

Gambatese, J. James, D Dust Suppression using a truck-mounted water spray system 2001

Journal of Construction Engineering and Management, V 137, n1

American Society of Civil Engineers

GCVTCRecommendations for Improving Western Vistas: Report of the Grand Canyon Visibility Transport Commission to the US EPA

96 Reports to the EPA Western Governor's Association

Grand Canyon Visibility Transport Commission

Gebhart, Dick L. Denight, M., Grau, R.H.

Dust Control Guidance and Technology Selection Key 99

US Army Construction Engineering Research Labratories, Land Management Laboratory

Gebhart, Dick L. Thomas Hale and Kim Michaels-Busch

Dust Control Material Performance on Unsurfaced Roadways and Tank Trails 96 USAEC Technical Report

US Army Construction Engineering Research Labratories, Land Management Laboratory

http://aec.army.mil/usaec/technology/dustcontrol.pdf

87

Primary Author Authors Title Year Name of Journal or Publication Name of Publisher URL

Gillies, J.A.

Watson, J.G.; Rogers, C.F.; DuBois D.W.; Chow, J.C.; Langston, R.; Sweet, J.

Long-Term Efficiencies of Dust Suppression to Reduce PM10 Emissions From Unpaved Roads

99Journal of the Air and Waste Management Association 49, 3-16

Air and Waste Management Association

JAWMA Paper: Long-Term Efficiencies of Dust Suppressants to Reduce PM10 Emissions from unpaved roads

Grantz, D.A Wind Barriers Offer Short-Term Solution to Fugitive Dust 98 California Agric., 53, 14

Hagen, L.J. Mostafa, N.; Hawkins, A.

PM10 Generation by Wind Erosion. 96Proceedings, International Confrence on Air Pollution from Agricultural Operations

Harding Lawson Associates

Evaluation of PM10 Emissions Factors for Paved Roads Prepared for Regional Air Quality Council, Denver, CO

91 Regional Air Quality Council, Denver Colorado

Harding Lawson Associates

Hewitt-Daly, Mary Overview of Fugitive Dust Emissions 2000 Malcolm Pirnie http://www.pirnie.com/docs/resources_pubs_air_may00_6.html

Holmberg, M. Soy Oil Ready to Eat Your Dust 89 Successful Farming, v 87, n 11

Hoover, J.M.

Bergerson, K.L; Fox, D.E; Denny, C.K.; Handy, R.L.

Mission Oriented Dust Control and Surface Improvement Processes for Unpaved Roads. Final Report

81 Iowa Hwy. Res. Board Proj. HR-151

Hubbard, S. J.Assessment of the current status of the environmental aspects of fugitive dust sources associated with mining

76 EPA PEDCO-Environmental Specialists

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Controlling Dust on Unpaved Roads 89 Rural Transp. Fact Sheet No. 84-02. T2 Program

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Controlling Dust: Which Materials should you use? 98 Better Roads, v68, n 6

Dust Contol, Road Maintenance Costs Cut With Calcium Chloride 90 Public Works, Vol. 121. No.6

Dust control fights erosion 92 Better Roads, v 62, n 10Guidelines for use and application of dust palliatives 90 Public Works, Vol 21, n 1

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94