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'irt'i-odaction- Page 1 of 111 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY UJ fftml version of the file httpT/A jVM^f?s/Dust%2QManual%20102704.pdf. automatically generates html v^Wrte'brr <!tec'a'mWt"s 3 3?'^/e crawl the web. To fin?; to or bookmark this page, use the following url: http://www.googie.com/search? q=cache: FCsvQJISjCwJ :www-personal . ksu . edu/-sstevens/Dust%2520Manual% EPA Region 5 Records Ctr. 2520102704.pdf+muleski+1986+dust+suppressants&hl=en Google is neither affiliated with the aniliiirs of this ptif>e nor responsible for I/A foment. 238805 nCPL'l'TOTIILlM ILHTIOH OP These search terms have been highlighted: muleski 1986 dust suppressants <div style="position:abso 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 Page 1 Recycled/Recyclable Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer) http://72.14.207.104/search?q=cache:FCsvQJI8jCwJ:www-personal. ksu.edu/~sstevens/Du. 11/3/2005

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'irt'i-odaction- Page 1 of 111

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

UJ

fftml version of the file httpT/A jVM^f?s/Dust%2QManual%20102704.pdf.automatically generates html v^Wrte'brr <!tec'a'mWt"s33?'̂ /e crawl the web.

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These search terms have been highlighted: muleski 1986 dust suppressants

<div style="position:abso

Dust Suppression onWyoming's Coal MineHaul Roads

Literature Review

Recommended Practicesand Best AvailableControl Measures - BACM

Dust SuppressantSelection Guides

A Manual

Page 1

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer)

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prepared for:Industries of the FutureConverse AreaNew Development

October, 2004

by:

Temple Stevenson

Page 2

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

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Pages

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TABLE OF CONTENTS

Introduction

Literature R e v i e w : Fugitive Dust and Its Control

II. Recommended Practices and Best AvailableControl Measures

Table 2.1 Dust Control Operations Recommendations 2Figure 2.1 Sample Air Event OutlineTable 2.2 Best Available Control Measures

BACM (Recommendations) For ControllingFugitive. Dust on Mine Haul Roads

II I . Dust Suppression Selection Guides

Table 3.1 Dust Suppression ProductsTable 3.2 Dust Suppression Applications GuideTab!e_3_._3_ Dust Suppression on Mine Haul Roads

Cost Worksheet (available in excel)

Appendices

Appendix A: Dust Suppression Siiryey_and_Res.u]tsAppendix B: Dust Control Plan and

Self Inspection ChecklistsAppendix C: P a l l i a t i v e Selection Matrix

(Thompson)Appendix D: Pa l l i a t ive Selection Matrix

i.Bolander andJYarnadjijAppendix E: F u g i t i v e Dust Bibliography

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PageS

Introduction

Fugitive dust emissions are increasingly becoming a problem for Wyoming's surfacmines located in a w indy semi and environment where the average wind speed is 1:miles per hour and the average rainfal l is a mere 14 inches with some of the highestevaporation rates in the nation. Fugit ive dust emissions are a nuisance in coal minesimpairs v is ib i l i ty , affects the health of employees, increases wear and tear of equipnand increases road maintenance and costs. Current drought conditions, elevated win

speeds, compliance wi th air qua l i t y and clarity standards impacted by paniculateemissions, a predicted increase in coal production, and increased Coal Bed Methaneoperations has heightened the concern.

Dust from surface coal mine operations also has the potential to negatively impactFederal Class 1 Air Quality Areas in the region, such as Badlands and Wind CaveNational Parks and the Northern Cheyenne American Indian Area. While no visibiliimpairment in these Class I areas is currently attributable to any Wyoming source, ii

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anticipated that strategies to maintain a status of minimal impact will be of notable >to the Western Regional Air Partnership (WRAP) and the State of Wyoming in thedevelopment of its Regional Haze SIP(State Implementation Plan), due by Dec 31, [(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 amitigation, so that efficient and effective management strategies for suppressing it cimplemented. The report includes four segments: I. Literature Review, II. RecommtPractices and Best Available Control Measures -BACM; III. Dust Control SuppressSelection Guides; and an Appendices containing a fugitive dust bibliography ajiddocument examples.

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IV

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Page?

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 transfers93% oft

and loading, and topsoil handling are all contributing factors of emissiondust generation in a coal mine. A South African study conducted strip mir,in an arid climate similar to Wyoming's by Thompson and Visser contnbu

transpor(2002) titled "Benchmarking and Management of Fugitive DustEmissions From Surface Mine Haul Roads" determined that 93% of the total dustemissions from a coal strip mine could be contributed to coal transport or haul roadjFigure 1. illustrates their findings of the contributions of specific sources of fugitiveas a percentage of the total fugitive dust generated by a surface coal mine.

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 acthe complexity of various interactions. The interactions include traffic volume, weigclimate, and more according to Thompson & Visser (2002). They add, "most surfac

l-i « . +- -P« •«•» r

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imnc upciaiuis agicc mai uusi-ncc luaus me ucs>nauic, uiu imu u uiiiicuu tu

into cost-effective management and mitigation." This same study found that regularwatering and the application of chemical suppressants in conjunction with optimalaggregate surfaces is the only effective option for controlling fugitive dust emissionhaul roads.

The most harmful types of fugitive dust to the respiratory system are those that are i10 microns in diameter, known as PM |0 's. Because they are most harmful, the>

Pages

most monitored. Another common measurement involves total suspended particulatTSP's. Total suspended particulates refer to the total amount of solid particulates anliquid droplets suspended in the air, regardless of particle size (Ferguson et al., 1995Wyoming has been monitoring PM m emissions to meet Federal standards sincebefore that TSP's were the only monitored emission.

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

Dust Suppression Planning

When a coal mine is in the process of implementing a dust suppression plan, cost aiplays a large role in product selection. When looking at a product, an overall cost anshould be taken into account. According to Bolander and Yamada (1999) in a reportthe US Forest Service entitled "Dust Palliative Selection and Application Guide" asuccessful dust control program should not only reduce total dust emissions, but it:also reduce maintenance costs. Some dust control products have proven that they asignificantly reduce overall road maintenance costs and thus achieve an overall saviAt the same time additional preparation and a change in maintenance practices mustaccounted for. A booklet published by Environment Australia, a branch of AustraliaDepartment of the Environment and Heritage, Dust Control Best Practice Environn.Management in Mining (1998), explains the benefit of a dust control plan as "a lonjview of dust control has proven consistently cost effective. Mine planning has aparticularly important role to play in dust control. Applying controls after the probh

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arise is often difficult, impractical or costly."

Haul Roads/Unpaved Roads

Fugitive dust is derived from a variety of sources; nonpoint sources such as un-vegesoils, and specific sources such as haul roads (Environment Australia 1998). Dustgeneration can be defined as the process by which paniculate matter becomes airboiThe amount of dust that becomes airborne is a function of various factors; includingsusceptibility of the surface material to wind and water erosion, and the erosive actitof haul trucks (Thompson & Visser 2002). If this latter human activity coincides wiiunfavorable weather conditions, the result can be greatly increased dust emissions(Ferguson et al., 1999).

Haul roads generate significant amounts of dust emissions (EPA Fugitive L1992; Thompson and Visser, 2002).

There have been several studies completed to estimate the emission rates of PMunpaved roads. According to Bolander and Yamada (1999) in the USForest Sevice Report, Dust Palliative Selection and Application Guide, the followindust generation 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 determiithat a vehicle traveling on a untreated unpaved road at a speed of approximately 25

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i»ci«ccii u._>v 10 _.tn> no ui r.vi 10 eiiiibbiuiib per vciucic uuies uaveic(Gillies et al. 1999). When that vehicle's speed \vas increased to 35 mph the emissicrates increased to 1 .85 to 3.04 Ibs. PM K. VMT with an uncertainty of 0.23 Ibs.VMT. Other studies have fourd similar emission results. Flocchini et al.(1994) suggthat reducing vehicle travel speeds on unpaved roads from 40km/hr to 24 km/hr rediPM ,0 emissions by 42 + 35*7

The Environmental Protection Agency, reporting in Compilation of Air PollutantsEmission Factors Volume 1 Ch 13. AP-42 < 19981. found that emission of fugitive dihaul roads is highly correlated \ \ i th vehicle weight and silt content of the surfacematerial. The study reported that a si l t content mean of 8.4^ of fines on a haul roada mean of 24*7 was found on a freshly graded haul road. This indicates a significantincrease in fines after a road hjs been graded.

In addition to these factors the EPA also suggests that other traffic characteristics shbe considered: such as the cornering of trucks, the road's bearing strength, and gradi(EPA, 1998. AP-42). They also suggest a complete examination into climate conditilike freeze/thaw cycles and month l\ average wind speeds.

Effective dust control on haul roads in the Powder River Basin is complicated by ththat stretches of road, constructed of less than optimal aggregates, are subject to higitraffic volume by heavy haul trucks, which requires continuous grading and the freqaddition of new surface material. Wearing of surface material is related to a numberfactors including wind speed at the road surface, traffic volume and tonnage, type olaggregate, compaction of the road, amount of spillage, and climate (Thompson & V2002).

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 muchdifficult to control. (EPA Fugi t ive Dust. 1992). The EPA has devised numerousequations to estimate emissions both from unpaved roads and from storage piles. Thequations can be found in "Fugitive Dust Background Document and TechnicalInformation Document for Best Available Control Measures" published by the EP/September of 1992.

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In a report by the U.S Army Construction Engineering Research Laboratories Gebh;al.(1999) noted that chemical suppressants should be considered as a secondary sotin controlling dust. "A properly maintained road with adequate drainage to create aroad surface should be the first step and must be implemented to the greatest extentpossible. The best way to avoid a dust problem is to properly maintain the surface, ;that is achieved by grading and shaping for cross sectional crowning which preventsgeneration caused by excessive road surface wear." It should be noted that this stud?to contend with heavy vehicles with tracks, such as tanks, which reduced the efficie]and cost effectiveness of any dust suppressant.

Effectiveness of Dust Suppressant Measures on Unpaved Roads

When analyzing dust control effectiveness it is hard todetermine a product's direct impact due to the large number cmK* du

of compounding variables (traffic volume, truck weight and t i ff 'speed, road type, etc.). This is further compounded by the go% when ajfact that there is not a uniform standard for determining dust intervals of rsuppressant effectiveness (North Carolina Department of month (EPA,Environment and Natural Resources Division of Air Quality e e ectlve

(2003). Most assessments available are based on qualitative depends on tldata not quantitative data (Sanders & Addo, 1993). "Without the appiicatkany quantitative dust measurement, it is difficult if not between app]impossible to assess the economics and lasting value of dust amount, weijpalliation methods," (Sanders & Addo, p. 1 1 , 1993). There traffic' metec

conditions, aare generally two areas of study concerning measuring or .analyzing dust. The first is atmospheric modeling andprediction, and the second is field measurements and quantifications (Sanders & Ad1993). Field studies are generally more helpful in determining actual effectiveness;however there are numerous factors that need to be considered. Because of the diveiof site characteristics, it is difficult to recommend a suppressant that will work wellsituations.

In many instances the only gauge of the effectiveness of a product is either the resulfrom manufacturer's testing or testimonials from previous users (Engle, 2004). Everit is hard to determine if the product is going to work in a particular area with possitdifferent aggregate type.

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The follow in? is a summary of some of the significant studies that hme been conducregarding the relative effectiveness of dust control measures.

Thomas Sanders, et al.( 1997) conducted a study at Colorado State University on un]road sections in Larimer County. Colorado to try to determine the relative effective!of the three commercially available dust suppressants. These researchers evaluateceffectiveness of lignosulfonate ( l ign in ' ) . calcium chloride (CaCl :k. and magrchloride (MgCl ; against a section left untreated. They based their evaluation on tffundamental measurements: traffic volume, fugitive dust emissions, and total aggreloss 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 thrthe treated sections outperformed the untreated section. Total aggregate loss wassignificant!) higher for the untreated section, in fact it was 3 times more than the M;2.7 times the lignin'. and 2 times the CaCl :. Relative fugitive dust emissions vhighest on the untreated section. Based on cost to replace aggregate lost, traffic volucost of maintenance, and cost of suppressants they concluded that lignin' and MgCan identical cost per mile per year of S21 vehicle, while CaCl ; was at $26 aruntreated uas up to $36. They produced the following chart to highlight the cost an;(ADT is the average dailv t raff ic) .

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(Sanders, et al. p. 396, 1997)

Based on these results, the group concluded that under high temperature and low relhumidity lignosulfonate appears to lessen the amount of dust produced. They also fithat lignosulfonate and MgCl 2 had the least total aggregate loss at 1.0 t/mi/yr/vestudy found a 28-42% reduction in annual maintenance cost for the treated sectionscompared to the untreated sections.

However, during a personal interview with this author on March 30, 2004,1Sanders stated that he felt the MgCl 2 was the superior product based orlong 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, CaCl 2 and MgCcontrolling dust. They used a crushed gravel stone from Wyoming in one segment cstudy. This gravel contained approximately 9.9% fines, less than both the Texas andArizona samples. They prepped the aggregates by allowing them to cure for 2 days ;32C and 35% relative humidity. They then sprayed the samples with water at a rate1.8 L/m to reduce the surface tension and increase the rate of penetration, and nexapplied magnesium chloride to one sample, calcium chloride to another, and water cto another sample. They found that applying chemical palliatives (MgCl 2 :the Wyoming aggregate had a statistically significantly effect on reducing erosion c;by wind. This, they determined was related to the fact that the chemicals kept the suwet even in windy conditions. The authors found no real difference between the Mgand CaCl 2, but noted that both lose their effectiveness over time.

Next they evaluated the effectiveness of the chemicals in a simulated traffic experirrThey found that a 38% solution of CaCl 2 and a 30% solution of MgCl 2 app

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Wyoming aggregate significantly reduced erosion caused by traffic compared to anaggregate sample that was only treated with \vater. They concluded that the applicatof CaCl ; or MgCI : greatly enhanced dust control on unpaved roads in comparisoiwater or no treatment and that there is not a significant difference between the twochemicals.

Gillies et al. < 1999) from the Desert Research Institute at the University of Nevada ithe San Joaquin Valley Unified Air Pollution Control District evaluated the effectiviof four dust suppressants over a 14 month study. The suppressants that were testeincluded a biocatalyst stabilizer (EMC "). a polymer emulsion (Soil Sement), a ]emulsion w i t h polymer (Choerex PM). and a nonhazardous crude-oil-containing maThe study identified an equation to calculate suppressant control efficiency, which tdefine as "the percent reduction in emissions between the treated and untreated secti

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

This study determined that estimating suppressant efficiency can be done using somsimple methods in place of expensive monitoring. The authors determined that ameasurement of the bulk silt loading and the surface strength can provide an effecti'inexpensive assessment of a suppressants effectiveness to reduce PM i0 emisuppressant treated surface that can achieve bulk silt content less that 20 g/m2 isconsidered to he 90** effective at suppressing PM 1{t emissions. Further, if tha'maintain flexibility (measured by a penetrometer) and can resist brittle failure then tsuppressant is predicted to maintain effectiveness longer (Gillies, et al. 1999).

Effectiveness results The bio-catalyst (EMC ") was only 39% effecthafter the initial application and 0% effective after 11 months. The acrylic ccpolymer was 95% effective after one week and approximately 85% after 11months. The bitumen product was 95% effective after one week, 75% aftermonths, and 53% after 11 months.

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The EPA has created an equation to determine the PM ,0 emission factor for iroads. This accuracy of this equation, however, is still under some question, particulrphtteH to \ .ehi(-le «IVPI| I \lnlp<;Li '\!RI "(00"ll Alsn this ennntinti it rtf^ioncrl nrniiut

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. _*.».,«. *- v~ . _ . .. ^» — ~£, ~ — — ^i. ._._.«_»« * . --. »— _ W V _ ^ . *.*..»_ ... VVU _.J „„., W . - -~ »V_..Q.., .^»~ — . ^ ......

average traffic weight, and does not account for heavier trucks {e.g. haul trucks).

E=2.6 (Silt/12)A0.8 (Weight/3)A0.4 / (Moisture/0.2)A0.3)

E = PM 10 unpaved road dust emission factor for all vehicle

Silt = silt content, material less than 75 /zm in the surface materWeight = average weight of the vehicle fleet (tons)Moisture = surface moisture content (%) (EPA, AP

The addition of moisture into the equation is fairly recent (Countess, 2001). It was abased on the recognition that climate and moisture play a large part in overall emissfrom unpaved roads. An older version of this equation included variables for the nuiof wheels and speed, but re-analysis proved the variable not to be statistically signif(Countess, 2001). However, when using this model in an industrial setting it may beimportant to account for total wheels, traffic volume, and speed as variables. In addisome feel that the type of aggregate should be included as it can often account for thlong term amount of fines in the road surface.

Dust Suppressants

Road dust suppressants have evolved notably. Second and third generation producnow solving not only the dust problem but also cost efficiency, environmental, andissues (Engle, 2004). Positive results are now coming from even the toughest desertdrought environments where past products have failed (Engle, 2004). While EPA (P42, 1998) testing has shown that chemical dust suppressants can be effective (80%reduction when applied at regular intervals) there is not a single, cure-all solution. Sproducts work better in certain climates, various road surfaces, and under different tvolumes, and each product comes with various advantages and limitations.

Dust suppressants are effective based on the fact that they agglomerate the fine paiin a road surface, binding the surface particles together, and increasing the density ohaul road surface material (Bolander & Yamada, 1999). If fines are lost as dust on iunpaved road it leads to the coarse material coming loose and can then be thrown orwashed away. This can result in a road full of corrugations and potholes that requireexpensive maintenance (Sanders & Addo, 1993). "The main goal of a dust control istabilize the road surface; reducing the rate of aggregate loss and money spent annu;replacement," (Sanders & Addo, 1993).

Dust control additives are beneficial not only at reducing dust emissions, but they aimprove the compaction and stability of the road. According to Epps and Ehsan (20»there are numerous factors related to the effectiveness of a dust palliative includingapplication rate, method of application, moisture content of the surface material dunapplication, palliative concentrations fines content, mineralogy of the aggregate, amenvironmental conditions.

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Page 14

Surface treatments to control dust emissions fall under two categories, wet suppressand chemical stabilization (EPA. AP-42. 1998). Wet suppression includes wateringthe application of surfactants that keep the road surface wet. Chemical stabilizationinvolves an attempt to change the physical characteristic of the road. Unlike waterinchemical suppressants require less reapplication and many act to form a hardened isurface (EPA. AP-42. 1998).

The addition of a wetting agent or larger sized particles reduces credibility only at tlinterface of the surface and the impact vehicles (Thompson & Visser 2002). Dust ameasures lose effectiveness on a scale ranging from immediately to weeks. Thepalliative effects of water decays from lOO'r to 0<£ in a matter of hours while chemapplied to control dust may decay over several days or weeks so it is important tounderstand 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 LocTransportation Assistance Program states that in areas of high traffic volume, the codust control can more than pay for itself. This is based on the fact that a good dust <agent can not only reduce material lost from the road, but also reduce the need for bmaintenance (Skoreth & Selirr 2000). The same study determined that when a dustsuppressant is not working \\e!l aggregate fines are lost, leaving only gravel size paion the road, w hich leads to the formation of a washboard surface, reduced skid resisand potholes. The addition of agents (\\ ater or chemical) to reduce credibility is bas>the principle of increasing binding of the fines and gravel. (Thompson & Visser 200

According to "Surface Mine Dust Control" by John Organiscak. et al. (2003). the bxdust control plan should be dependent on the type of aggregate you have on your haroad. Selecting a dust suppressant, according to Sanders (1993) should depend not (on its performance characteristics, but also on the type of traffic and volume, roadwconditions, and the costs involved to achieve the desired level of control.

In the follow ing selection and application guide. Bolander and Yamada (1999) suggthat selecting suppressants involves determining not only cost but cost effectivenes

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iney nave ueviseu me lunuwing nst ui ueneiumg tauiurs mai snouiu oe cunsmeieuselecting a dust palliative.

Palliative Factors

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

(Bolander & Yamada, IS

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Water

Water assists in maintaining the compaction and strength of the roadand reduces the potential loss of road material (Thompson & Visser 2002).is attractive because it is seen as a cost effective alternative, however the cosoon escalates with the addition of expensive equipment and operating cost:

Data from the EPA's Compilation of Air Pollution Emission Factors VolunCh 13, AP-42 (1998) shown here in Figure 1.1 suggests that small increasesmoisture content (1 to 2 moisture level) initially results in large increases incontrol efficiency (from 0% to 75%) but beyond which additional efficienc;grows slowly with increased watering (requires 2.5x more water to increaseeffectiveness to 95%) significantly reducing cost effectiveness at the upper

Figure 1.1 Dust Control Efficiency of Water

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Similarly, a study by Rosbury and Zimmer (1983) found that watering oncehour has an efficiency of 40^ in controlling dust, but when that rate is douthe efficienc increases only by 15^ to 55

Re-application is required at frequent intervals dependent on environmentalconditions. Water retention in the Powder River Basin is generally poor duehigh temperatures and wind speeds as well as low relative humidity. Increa:

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w ater scarcity and cost adds to the scenario making water a temporary andt\pically un-economical solution.

Thompson and Visser (2002). based on the context of the arid South Africamines, determined the degree of dust control achieved by watering is a fumthe amount of water applied, time between applications, traffic volumes, wtconditions, wearing-course material, and the extent of water penetration inti

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wearing course. They determined that on an average degree of dustiness, a :reapplication is required at three hour intervals in the winter and every hourhalf in the summer. These intervals decrease with the addition of weight peivehicle, number of wheels, traffic volume, and climate conditions.

Thompson and Visser (2002) also found that traffic volume negatively comwith total dustiness; which they explained based on observation, that higheivolumes led to more compaction of the wearing course and the removal of iloose material on the sides of the road as well as spillage from the vehicle.r

also determined that vehicles lower to the ground with many wheels tend toan increase in dust based on the increase in wind shear.

Precipitation can greatly reduce dust emissions. Normally a rainfall resultirleast 0.1 inch is assumed to suppress all emissions. However during a hot, dsummer's day a rain of that same amount may only reduce emissions for heopposed to days (Countess, 2001).

Chlorides

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

Chlorides are the most commonly used products for haul road dust control. A study byRosbury and Zimmer (1983) showed that the highest control efficiency measured for achemical dust suppressant (at that time), 82%, was for CaCl 2 two weeks after cthen decreased over time. The average during the initial two weeks was approximately50%. After five weeks, the control efficiency declined to less than 20%.

The most common salts used to control dust are calcium chloride (CaClmagnesium chloride (MgCl 2)- When determining which is most effectivability to produce a brine under adverse conditions such as high wind speedhumidity, or high traffic volumes is the best indicator (Sanders, 1993).

CaCl 2

Calcium Chloride (CaCl 2)has been used as a dust control and restabilizing agent for the last century (Epps & Ehsan, 2002). CaCldeliquescent and hygroscopic properties causing the chemical to ha

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Page 17

high af f in i ty to \K ater: increasing the tension of water molecules besoil panicles. When applied the chemical increases the adhesive bobetween panicles resulting in retention of particles. According to Eal.( 2002) CaCl ; has a wider range of effectiveness in regards lotemperature than magnesium chloride and loses its hygroscopic prcat a temperature of 25C if the relative humidity drops below 32%.

Calcium Chloride comes in three forms: flake at 77-80% purity, pe97*^ purity, and a clear liquid at 35-38% purity (Bolander & Yama1999). Calcium Chloride is favored over Magnesium Chloride in aiseasons of higher humidity, but it is not as effective in long dry spe(Bolander & Vamada. 1999). This chemical can significantly loweifreezing point of a water solution. In fact at 30% solution can havefreezing point of -60F (Larkin Laboratory. 1986). Because of thisproperty several coal mines choose to use CaCl ; during the w

MgCI :

Magnesium chloride is a by-product of potash production and is onavailable in the liquid form (Ferguson et ai.. 1999). When determinCaCl : or MgCI : is more effective there are contradictory finding:statements. It seems the more recent studies are coming to the conethe MgCI : is outperforming CaCl ^ . According to Epps and EslMgCI : is more effective than CaCl : in increasing the surface Uwater molecules. Bolander and Yamada (1999) found that MgCIconsidered to be the best water absorbing product for drier climate.'because the chemical starts to absorb water from the air at 32% rehhumidity regardless of the temperature. The product also increasesaggregate surface tension, creating a very hard road when the surfadr> . more so than CaCl ;

Both CaCl : and MgCI : are known to be corrosive to metals, because the;moisture to the surface and thus prolong the period of erosion (Bolander &Yamada. 1 999 ). A positn e attribute of both of these chemicals is that eachallots a maintenance creu to re-grade and re -compact with little concern f<surface moisture loss.

. irwuv, ...,.,

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vjcunaii ci a.\\\.yyy) siiiic mai mcsc bans jjiuviuc uic must saiiMauiuiy uicin

application ease, cost, and dust control for semi-arid, semi-humid climates.

Organic/Non-Bituminous Chemicals

Compounds under this category include lignosulfonate, sulphite liquors, talpitch, pine tar, and vegetable oils. These products generally perform well inenvironments but are not very effective when applied to aggregate surfacematerial with few fines (Gebhart, et al., 1999). These dust control agents ca

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very sticky and may harbor an unappealing odor. They often fail after heav;due to their water soluble, organic nature (Gebhart, et al., 1999). These proccurrently appear expensive, but the cost benefit equation continually changea rule, they tend to be environmentally friendly. One compound with somesupporting literature is lignosulfonate (lignin').

Lignin'

Lignin' or lignosulfonate is a by-product of the paper making proais regarded to be generally safe environmentally because of the faciis an organic product. This product performs very well under aridconditions. It binds particles together to increase the strength of theand remains effective during long dry spells with low humidity (Be& Yamada, 1999). One of lignin's weaknesses is that it is highly scin water, and its surface binding properties can be destroyed by heaIt also has a tendency to stick to passing vehicles and is difficult tofrom painted surfaces (Frazer, 2003). Lignin is most effective and sthe greatest longevity when the road has been scarified and the proibeen mixed into the aggregate (Sanders & Addo, 1997). However,this same scarification process that reduces the current use of lignitsome haul roads, as the perceived costs of the down-time due toscarification and curing appears prohibitive.

A study using lignin' on Pikes Peak's unpaved roads conducted by

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Sanders and Addo (1998) revealed that the lignin was 2.7 more eff<at suppressing dust than water. After spring snowmelt. 8 months alapplication, there were indications that the Lignin" was still functioa good proportion of the test sections.

Petroleum Products

Petroleum products include asphalt emulsions (modified and not), dust oilsfluids, and petroleum resin emulsions. These products may be effective in avariety of climates; houe\er. because they are by-products of petroleum anwaste oils, they may contain toxic materials with significant environmentaleffects, and are not considered safe unless they have been processed to rermtoxins (Gebhart. et al.. 1999). These products are usually very expensive anthe organic products, are very sticky and have a foul smell.

Petroleum products are film forming and dust binding. They coat the dustparticles and form a cohesive membrane that attaches each to adjacent partiThis results in a chained bond of large agglomerates that are too heavy to txdislodged by wind (James Informational Media. Inc.. 2000V

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Emulsified Asphalts

Emulsified Asphalts uork to control dust, but their use is very limithe product must be applied with specialized equipment (Skorseth ;Selim 2000). The soil t\pe and density of the road surface can greaaffect the rate at u hich a petroleum product penetrates the road. Rethat ha\e been scarified to loosen the aggregate achieve the greatesamount of soil penetration. If the road has not been scarified the us<products \ \ i t h lou viscosities will be ineffective (Bolander. Yamad1999)

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Polymers

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

Electro-Chemical Stabilizers

Electro-Chemical stabilizers include sulphonated petroleum, ionic stabilize]and bentonite. They are not likely to leach out and are stated to be very effeat reducing dust emissions in clay or sandy aggregate types. These product:well under a variety of climate conditions; however, many of these product!not been tested using standard laboratory tests under field conditions. Smalltrials should be performed to determine site specific efficiency prior to larg<scale usage (Gebhart, et al., 1999).

Surfactants

Essentially surfactants are additives that make water wetter, reduce surface tension <allow better penetration of the palliative. At least one product (Haul Road Dust Conclaims a cumulative effect, whereby each new application boosts the effectiveness oprevious levels.

Several manufacturers of surfactants recommend prewetting of the roadbed, for theiproducts to perform optimally. Similarly, Epps and Ehsan (2002) used prewetting intheir laboratory study of aggregates and erosion.

There is a slight trend within mine operations in the Powder River Basin to use highdiluted applications of MgCl 2 and CaCl 2 in all water applications, instead of a ;

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There are environmental concerns associated with the use of certain surfactants, (refpage 17 of this document for a discussion of these impacts)

Other Commercial Products

A list of commercial products is posted b\ The New Mexico Environment/ Departrrof Air Quality Bureau, which can be accessed on the web athttp://ww\\.nmenv.state.nm.u>/aqb.'dust_control,_htrnl.and in Table 3.1 of this reportThere are some products listec here that are not included in this literature review.Classification of every product is not possible in part due to lack of a literature histoand to the proprietary nature of the commercial formulas.

Mechanical Stabilisation

Mechanical or road stabilization is the mixing of two or more substrate materials toa road surface that has the correct fine gradient and plasticity. This method does notinvolve the application of chemicals although they can be used in addition to thestabilization. One of the most effective substrate mixtures involves the addition of cto a gravel and sand aggregate. The clay binds to the fine particles, and improves th<roads stability and longevity. "When a gravel road resists lateral displacement durintraffic, it is said to be mechanicalh stable, notes Gebhart. et al. (1999). This resistanprovided b> 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 acontrol plan. "It can translate either into success or costly wastefulness, failure, anddifficult maintenance down the line." according to David Engle (2004). author of '7Mainteminct' Tcchniijufs and Pi-mind <> ILiM- Made Great Strides." Engle alsoemphasizes t iming as a critical component to successful application. He suggests aninitial application during the narrow window between the spring rains and the start (summer drought; "Keeping an e\e on the weather forecast is critical: many expenseapplications ha\e been ruined r>\ ra infa l l . "

Not only is the t iming of the application crucial, but the manner in which the producapplied is just as important - if not more so. Sanders and Addo (1993) describe twoin which suppressants are most t \p ica l ly applied: mixed-in-place and spray methotThe mixed in place method invohcs mixing the suppressants with the road aggreg;When this application procedure is used it not only suppresses dust but it also provifor an impro\ed road surface resu l t ing in reduced maintenance costs. Spraying invothe high pressure application of the material to the road surface. Topical spraying isorr ^y»t * * • A t i-^r- .- ht s*vv4 »xj»^i i^s~\ c *-vl t « r>^ .•* »V-* / - \ i i nV-* T-.ar- 11

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u ivji aiiuii pv^i luua \ji uuii/, muugii, i^auiuug in ui^ nisi/u i\ji

throughout the season (Sanders & Addo, 1997). It is usually wise to try a test sectioidetermine how well the product is going to work on a specific gravel, and what typeapplication works best (Skorseth & Selim, 2000).

Almost all suppressants have a greater longevity and effectiveness when applied }o a roadthat has been properly prepared, scarified, and the suppressant is mixed in with theaggregate 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). 1suggest that adequate penetration of the dust suppressant into the surface material isimperative. This penetration should be 3/8 to 3/4 of an inch in depth. Proper penetrawill reduce the loss of palliative from surface wear and allow the surface to resistleaching. The process imparts cohesion, and resists aging.

Bolander and Yamada (1999) in the USFS Dust Palliative Selection and Applicatioiprovide the following suggestions for applying dust suppressants:

Application Tips

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

• Apply suppressants (especially salts) immediately after the wet s• 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 applicatit

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 ofimportant techniques to be considered when applying dust suppressants arparticularly specify the technique when using lignin. Organiscak et al. (200:suggest that when using chlorides it is beneficial to loosen 1-2 inches of theaggregate uniformly to allow the chemical to penetrate evenly. And like Bo

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and Yamada (1999). the group stresses proper road preparation as a key to teffectiveness of a dust pall iative, especially creating a good crown and draiwhen using a chloride. They also state that when using a chloride the roadwshould not be compacted before applying the chemicals and the road shoulckept at optimum moisture before application, this allows the product to beabsorbed quickh and evenly.

For some suppressants it is recommended to keep traffic off the road surface for twthree hours after application tc allow the product to absorb and cure (Skorseth & Se2000). This characteristic is expected to be considered a limitation by mine engineeiwho would have difficulty just i fying the necessary down time involved on mine hairoads (see survey results. Appendix A). Grading after application also partially destithe effect of many dust suppressants (Ferguson et al.. 1999). Because of this, gradishould be postponed after heavy application of suppressant for as long as possible.

The EPA has recommended that a diluted reapplication be applied periodically (2 wto a month) to control loose surface material. Thev also state that weather related

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application schedules should be considered prior to implementing a dust control prc(EPA Fugitive Dust. 1992).

The type of road aggregate is one factor that determines the type of dust control thamost effective. Organiscak et al. (2003) recommend effective applications for varioiroad types in their article "Surface Mine Dust Control." In road surfaces with poor sgradation, water is the only ef fec t ive solution because chemical suppressants (mosiwhich are water soluble) cannot compact the surface or form a new surface becausew i l l leach. In sand the> recommend bitumens because of the fact that they are not wsoluble. On a road with good gradation all chemical suppressants can be used, androad wi th too much silt the road should just be rebuilt, as no dust control w i l l be eff(Organiscak. et al.. 2003). If a naul road is left untreated by a dust suppressant aggnreplacement w i l l become necessan over shorter periods of time and maintenance wrequired more frequently (Epps & Ehsan. 2002).

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Education and Training

In addition to using prescribed application procedures, John Watson and JuiChow (2000) from the Desert Research Institute suggest that the success ofcontrol problem depends on outreach and education programs for contractopublic works agencies. In a coal mine, education should be extended tomaintenance personnel.

Environmental Impacts

The major environmental concern when using dust suppressants is contamination (ground and surface water. Thomas Piechota, an assistant engineering professor atUniversity of Nevada Las Vegas was quoted in Lance Frazer's "Down with RoadD,(Innovations)" as saying it doesn't matter what suppressant is used, there will alwaysome level of water quality impact (Frazer, 2003). Peichota noted that petroleumcompounds were more harmful than suppressants such as magnesium chloride. Anarea of impact he mentioned is the fact that the suppressants are creating a somewhimpenetrable road surface, which will increase runoff, which has its own hydrologicimpacts.

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 thatchemicals are kept away from water sources.

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The following photo taken in June of 2004 in Larimer County, Colorado between L;

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unvj i __ 3tw.> i iiir\ 3u t_m^i « 3u2^^v~.ti-3 i uiiv.' 1 1 1 1 win u ui£^n vi a » u t.<ii\,u w mi a ~>\J /i duiuiu

Sodium Chlonde (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 thaiknow of. the expected negative publicity from this environmental impact (near Boulmay camo\er into other road salts such as MgCI : and CaCI : which are hea\There is no scientific evidence yet of the actual cause of the tree damage, but the dieappears to be confined to an area u i th in 50"of the roadway for 20 plus miles, strongsuggesting road runoff and/or exhaust fumes as contributing factors. Conversely, fe*Wyoming coal mine haul road-; traverse timbered acreage, limiting this specific imp

Surfactants, on the other hand. ma> pose some environmental concerns. M. Warhun(1995) in a report to Friends of the Earth. England, outlines toxicity concerns withalkylphenol ethoxylate < APEO) surfactants, and calls for a more widespread ban onuse (The surfactant is currently banned in several European countries). He recommethe replacement of APEOs w i t h linear alcohol elhoxylate surfactants, which are reacbiodegradable according to Consultants in Environmental Sciences Ltd (CES, 1993',

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Works Cited

Anonymous Colorado Department of Transportation Official. Personal Interview wiAuthor. June, 2004. Boulder, CO.

Bolander, P., Yamada, A. (November 1999). "Dust Palliative Selection and AppliceGuide." United Department of Agriculture, Forest Service, Technology and Develo]Program. San Dimas Technology and Development Center, San Dimas, California.

Countess, R. et al. 2001. Methodology for Estimating Fugitive Windblown andMechanically Resuspended Road Dust Emissions Applicable for Regional Air QualModeling. Paper in International Emission Inventory Conference, "One AtmosphereInventory, Many Challenges." Denver, CO, April 30. (Power point presentation slid

Engle, D. (2004). "Bidding Farwell to Dusty Roads. Road Maintenance TechniquesProducts Have Made Great Strides." Forester Communications, Erosion ControlJanuary/February 2004. www.forester.net

Environment Australia, Department of the Environment and Heritage (1998). "DustControl Best Practice Environment Management in Mining." SustainableIndustry/Sustainable Minerals.

Environmental Protection Agency 450/2-92-005 (1992). "Fugitive Dust BackgroumDocument and Technical Information Document for. Best Available Control MeasurOffice of Air Quality, Planning and Standards, Research Triangle Park, NC.

Enyironrnental Protection Agency (1998). "Compilation of Air Pollution EmissionFactors. AP-42. " Volume 1, Ch 13, Unpaved Roads. Office of Air Quality, PlanninStandards, 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.

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Frazer. Lance (2003). "Dcmn .Mth Road Dust (Innovations)." National Institute ofEnvironmental Health Sciences. Em Health Perspectives Dec. 2003 VI 1 1 i!6

Ferguson. J.H. et al. ( 1999). "Fugit ive Dust: Nonpoint Sources." Agricultural MU CUniversity of Missouri-Columbia. Agricultural Publication G1885.

Gebhart. D.L.. Denight. M.L.. Grau. R.H.. < 1999). "Dust Control and TechnologySelect ion Ke>." U.S. Army Construction Engineering Research Laboratory, LandManagement Laboratory. Resource Mitigation and Protection Division: and the U.SArmy Engineer Waterways Experiment Station. Pavements Division.

James Informational Media. Inc (2000). "Better Roads, a Look at Dust Control and 1Stabilizers." Better Roads Magazine u u v\ .benerroads.com/articles/prod500.htrn

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Larkin Laboratory (1986). "Calcium Chloride and Magnesium Chloride for DustControl." 1691 N. Suede Rd. Midland Michigan 48640

N. Carolina Department of Environment and Natural Resources Division of AirQu;(2003). "Economic Analysis of Paniculates from Fugitive Dust Emissions Sources.

Organiscak. J.A.. et al. (2003). "Chapter 5. Surface MineJhisLCQnirol." In HandboDust Control in Mining. Center for Disease Control. 1C # 9465.

Rosbury. K D.. Zimmer. R.A. > 19S3). "Cost-Effectiveness of Dust Controls Used 01Unpaved Haul Roads. Volume 1: Results. Analysis, and Conclusions." PEDCoEnvironmental. Inc. U.S. Bureau of Mines.

Sanders. T. t2004). Personal Inten. icu conducted by Temple Stevenson on the cam)Colorado State University. March 30. 2004.

Sanders. T G.. Addo. J.Q. (2000l. "Experimental Road Dust Measurement Device.'"Journal of Transportation Engineering. November/December 2000.

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Sanders, T.G., Addo, J.Q. (1998). Pikes Peak Road Dust Project. Colorado StateUniversity.

Sanders, T., Addo, J.Q., Ariniello, A., Heiden, W.F. (1997). "Relative EffectivenessRoad Dust Suppressants." Journal of Transportation Engineering September/Octet1997.p 393-397.

Sanders, T.G., Addo, J.Q. (1997). "Effectiveness and Environmental Impact of RoaiDust Suppressants." MC Report NO. 94-28, Mountain Plains Consortium.

Skorseth, K., Selim, A.A (2000). Gravel Road Maintenance and Design Manual. SoDakota Local Transportation Assistance Program. U.S. Department of TransportaticFederal Highway Administration.

Thompson R.J., Visser, A.T. (2002). "Benchmarking Management of Fugitive DustEmissions From Surface-Mine Haul Roads." Transaction of the Institute of MiningMetallurgy, Ill/April, pp A28-A35.

Watson, J.G., Chow, J.C. (2000). "Reconciling Urban Fugitive Dust Emissions Invtand Ambient Source Contribution Estimates: Summary of Current Knowledge andNeeded Research." Desert Research Institute, Energy and Environmental EngineeriiCenter. 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 Divis

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II. Recommended Practices and Best Available Control Measur

Best practices for dust control in a Wyoming surface coal mine simply means utilizthe most practical and effective methodology that is currently available. In many catbest practices can be achieved by appropriate planning and or the identification andcontrol 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 practicesdust control in a surface mine operation should include:

Planning

The identification of potential sources of dustA prediction of dust levels likely to occurAn evaluation of the effect of the dustThe incorporation of the dust predictions and control measures into mine p'and design

Observation

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

Controlling

An aware workforceIntegration of dust control into operations planning (construction, topsoilstripping, blasting)Intergrading dust control provisions into work practices (use of chemicalpalliatives)Monitoring and feedback dust emissions

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tttorts based on observational and qualitative assessmentsAwareness of current methods and technology used for dust control

f Environment Australia, 1998, p.<

The most effective, consistent and cost effective dust suppression strategy is a longplan that looks to control dust before the problem arises. Applying dust controls aftproblem arises is impractical and costly. Because of this, mine planning has a verysignificant 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 standardizedprocedures for application and maintenance. Standardized application this will miniconfusion on how the product is applied and maximize the product's effectiveness.,sound set of road application and maintenance procedures will result in safer workirconditions, a decrease in actual maintenance work, in addition to a decrease in ovenroad dust emissions.

The following quote prepared for ihe U.S. Army Construction Engineering ResearclLaboratories, highlights the fact that controlling road dust emissions should be seenprocess, not just the application of chemical palliatives.

"Tlie best way to avoid dust problems is to ensure that roads are properlvmaintained by surface grading ami shaping for cross-sectional crowning toprevent excessive road surface wearing and consequent dust generation.Chemical dust suppressants are considered a secondary solution, to be usedonl\ when maintenance practices have been implemented to the greatest exter,possible. " iGebhan. er al 1999. p. Wi

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Gebhart, et al. (1999) recognize three major types of dust control methods includingConstruction and Maintenance; (2) Mechanical Stabilization; and (3) ChemicalPalliatives.

Construction and Maintenance

Good construction and maintenance practices are fundamental to providing durableerosion resistant trafficked surfaces in dust-prone areas. Due to environmental and 1deterioration of the aggregate surface haul roads require frequent maintenance. Geblet al. (1999) suggest that the following construction and maintenance steps be perfoito prevent dust emissions on unpaved roads:

Use of a well graded aggregates consisting of an adequate amount of fines tcan 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 angrading.Reduced maintenance grading during dry weather conditions.

Creating adequate surface drainage should be provided in order to minimize damagtcaused by moisture. Standing water in the roadway will lead to surface softening an<failure (Skorseth, Selim 2000).

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Compaction of the road after adding aggregate and grading will increase th<density and strength of the wearing surface as well as retention of largeraggregates (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. Thi:type of resistance is attributed to the natural forces of cohesion and the internal frictthat arp nrpcpnt in thp cnil fOphhart pt al 1 QQQ l̂ Duct rnntrnl nroHurtQ nftpn havp a

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added benefit of increasing so:l s tabil izat ion. According to Skorseth and Selim (200"Gravel Road Maintenance and Design Manual." soil stabilization will control the l<of fines from the road surface that typically result in distresses such as wash-boardirreduced skid resistance. This type of unstable road becomes hard to maintain and hain new road aggregate with a higher percentage of fines becomes expensive. Aggresloss can be as much as one tor of aggregate per mile per year on a typical unpavedcounty road for each vehicle that passes oxer a road daily (Sanders. Addo. 1998) anilosses would be substantially higher on haul roads. A reduction in blade maintenancanother benefit of using a dust control product. When the road remains tightly bounstable it u . i l l require less maintenance (Skorseth. Selim 2000). Manufactures recomia delay in blading for as long as possible once a product has been applied because bcan 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 othermethods, especially if mechanical stabilization is cost-prohibitive and high dustemissions persist. When chemical dust palliatives are maintained over a long-term Ithere can be a 50-75<T or more reduction in dust generation. Gebhart. et al. (1999) fthat the dust control methods should be applied in the order discussed here: (1)construction and maintenance. (21 mechanical stabilization, and (3) chemical palliatin order to reduce dust emissions successfully.

Applying Chemical Palliatives

Before applying any dust suppressant, at minimum basic road maintenanceto be performed. Preparing a road before the application of chemical palliatshould include the construction of a good crown on the driving surface, gocshoulder drainage, and a fresh blading of the road surface to remove any poor other imperfections (Skorseth. Selim 2000). In addition scarifying the ro;order to loosen the soil a minimum of one to two inches can be done. This \leave a uniform depth of loose aggregate across the road will allow even anpenetration of the dust control product into the road surface. Several authorproduct distributors ha\e cited the need for scarification because of the add<depth of saturation it can provide. This deeper saturation is directly related iincreased dust control effectiveness. Although there mav be some added cc

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

Suppressant Application Tips

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

• Scarify the road to loosen the surface material to allow for evenpenetration of the product into the soil

• Apply suppressants (especially salts) immediately after the wet s(apply directly after a rain or pre-wet the surface prior to applic

• Adhere to manufacturer's recommendations on minimum applicarate, compaction and curing time

• Use a pressure distributor and realign the water nozzles on theapplication truck to ensure a even distribution of the suppressai

• Water frequently and lightly, not infrequently and heavily

Water as a Palliative and its application

Applying water on problem areas provides immediate but short tenresults. This inexpensive method of dust control is recommended ashort-term solution to dust emission problems (Gebhart, et al.,1995Water is effective at controlling dust emissions because the watersurrounds and adheres to the dust particle making it difficult for th<particles to move. However, under continual wetting conditions a pof the fine to the roads wearing surface may occur (Gebhart, et al.,1Excessive moisture on unpaved roads can lead to negative effectsincluding a reduction in the strength of the road bed, road deformatunder vehicle loading, and an increased potential for brittle failureproduces smaller particles that can then be crushed by vehicle tires(Rosbury and Zimmer, 1983). In the EPA's Compilation of Air PolEmission Factors Volume 1, Ch 13, AP-42 (1998) it is noted that siincreases in moisture content result in large increases in control effbut only up to a point, beyond which additional efficiency grows siwith increased watering.

Water droplet size has been shown to be an important factor in dus

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suppression effectiveness (Gambatese. James 2001). If water dropl>

too large, smaller dust particles generally just slipstream around thdroplets without actually making contact. If the droplets are too sm

just mix and circulate with the dust particles without actually wettithem. Small droplets may he negatively affected by wind and surfa

tension. An optimal water droplet size for surface impaction of fine

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paniculate agglomeration is approximately 500 um. To create an elwater spray system hollow cone nozzles which produce the greatescontrol of dust while minimizing clogging should be used. Anglinjnozzles on the truck body in a horizontal angle or lower will protecdroplets from wind.

Application practices issues

There can be other problems that inhibit the effectiveness of using a dust controlpalliative. These include a lack of communication between water truck operators,applying a product where not needed (such as shoulders and berms). and confusionthe desired outcome of using the product. The information in the following chart is Ifrom a presentation prepared by Rose Haroian. Environmental Manager for the Po\vRiver Coal Company: and is helpful in addressing some of the operational problemsare encountered when using a dust palliative and or water to suppress dust.

Table 2.1 Dust Control Operations RecommendationsProblem SolutionWater truck-, aren't s>TKhromzed Communicate between water trucks to

where watering has and hasn't taken pi

Operators are seeking dust elimination rather than Maintain an understanding of what thedust control of w atering is. and have indicators that

w hen the roads need watered. Sometirr

indicators are not accurate.

Roads treated w ith dust control products are heing New 1> treated roads only need water wwatered loo much become visibly dusty.

Coal Dust cau-^J b> spillage Do not attempt to apply water to coal s

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Over watering creates more dust

Spraying water in high wind

Soft Spots

Sprayers are not properly positioned

Watering inappropriate areas such as berms

Blades blade off watered areas

Blades blade rock and chemicals into ditches

the spillage insteadCommunication needs to occur betwee:and water truck operators, don't waterneededAdjust speed and location on the road twind.Don't over water, spot watering in thewill cause road problemsModify sprayer locations to ensure theoptimizing the desired spray areaWatch where you are watering. RelocaIf this does not work turn off the outsic

Blades should only blade where it is ne

Carry windrows across the road. Do ncchemicals and scoria in the ditch

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Real Time Data - Monitoring

Visual indicators to perceive dust emissions problems are a useful techniquhowever it is hard to keep an eye on dust emissions 24 hours a day. The colof real-time dust emission data from air quality monitors is important. A rePM 10 emission inventory is required for the state's SIP and is logical so thesource specific dust control measures can be taken. The dust may be comiran overburden pile or a county or coal bed methane (CBM) road, so automawatering of the haul road would be inappropriate. The use of real-time dataincorporated with the notification of personnel and a record of where the dicoming from as well as weather conditions can create can create a higherunderstanding and accountability of dust emission exceedences.

The mnnitorinp network for narticnlatp, emissions in the Powder River Rasi

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extensive; operating since 1989, according to Wyoming's Long Term StratcVisibility Protection: 2003 Review Report (Wyo DEQ, 2003). Additionalmonitoring, including that of meteorological data is conducted at IMPROV(Interagency Monitoring of Protected Visual Environments) locations.

Figure 2.1 illustrates a sample protocol used by one mine to be followed ba;various types of exceedences and events (aided by real-time data).

Figure 2.1 Sample Air Event Outline:

Air Event Logging and Action Levels ( Mine. WY)

If ug/m level = 300 (over 1 hr)

(I) notify production supervisor

Supervisor's actions include:

ensure adequate water trucks operating

record water usage for this shift

ensure problem areas are addressed

notify

If ug/m level = 80 (24 hr rolling average)

(1) notify production supervisor

Supervisor's actions include:

Same as above, plus:

Estimate wind speed and directionConsider modifying plant operations contributing to dust

Inspect dust generating segments of operation to ensure proper dust control

Document conditions including offsite impacts, meteorological conditions

Document actions taken

Take photographs to document primary sources of dust (on or off site)Notify Senior Environmental Engineer if cause of dust event cannot be identified

If ug/m level = 100(24hr)

(1) Notify Operations Manager(OM), who will notify Sr. environmental

engineer (SEE)and production coordinate^PC).(2) Notify General Manager (GM) if curtailment of operations is expected

If ug/m level=150 (excursion event)

(1) Notify the Environmental Manager as well as OM, SEE, and PC, and GM.

(2) Contact the Wyoming Dept of Environmental Quality by phoneActions to consider

Curtail production operationsContact neighbors contributing to dust impact (county roads, landowners

Water/suppress dust on any identified problem areas

Document actions taken

lfug/mlevel=120(24hr)(1) Notify same as above (150 level)

Contact Environmental Manager

Contact President

Contact the Wyoming Dept of Environmental Quality by phone

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rropeny applying ana maintaining a oust control product can DC more important in;selecting the perfect one because the manner in which a product is used directly relahow effective the product will be. Cost-effective dust control depends not only onapplication but also on proper maintenance and regular reapplication. Properly usinjdust control product can reduce the amount of grading that is required, decrease theamount of road aggregate that is lost, and reduce vehicle wear and tear. Ultimately £these benefits result in a savings of time and money, which is illustrated in Table 3..this manual.

A BACM recommendation from Dona Ana County, New Mexico (2000) can besummarized as Smart Timing and involves the timing of either operations or palliatiapplication so as to prevent the most likely exceedences due to meteorologicalconditions.

The Arizona Department of Environmental Quality (ADEQ, 2001) notes thattechnological and economic feasibility is a valid criteria for determining BACM ancthat BACM will change as new products and approaches are proven technologicallyeconomically feasible.

Gaffney and Shimp (1997), in a report for the California Air Resources Board, call 1improved GIS technology to calculate and spatially analyze emissions.

In compiling BACM recommendations, the author visited with mine engineers. Toascertain the opinions of surface coal mine engineers in the Powder River Basin rehto dust suppression on haul roads a survey was developed and distributed. Five respwere 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 re\of the literature and analysis of the fugitive dust situation facing Wyoming surface <mines. Mine representatives, agents from the Wyoming Dept of Environmental Quaand Region 8 of the EPA, and other appropriate parties should review and discuss thstrategies for technological and economic feasibility and expected effectiveness bef<final BACM list is completed.

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

Keywords

MonitoringReporting

Monitoring

Reporting

Controlling

Inventory

Monitoring

Controlling,

Documenting

Recommended Practice

Develop a protocol (similar to example given in Figure 2.1) for notification of appropriate plarpersonnel and environmental agencies (e.g. Wyoming Department of Environmental Quality) i

reaction to various dust events.

Develop a report template for documenting and reporting dust events

Be prepared to supplement current water truck fleet with rental/vendor (rucks to ensure noexceedences occur

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

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 £varying climatic conditions. Become aware of emerging technologies.

Documenting Closely document water usage along with climatic conditions (current effectiveness of water is

controlling 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 is

training, Periodically conduct personnel appropriate training in dust monitoring and suppression. Ensur

communication 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 predict

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ControllingControlling

Controlling

muuipuiaic \jio inuucllllg imu uusi cunilui planning.

Maintain equipment in optimal condition (e.g. spray nozzles)

Follow proven or recommended palliative application procedures (e.g. surface prep, applicatiorates and times, curing, compaction and grading)

Take action to reduce spillage from haul trucks, as coal and overburden spillage destabilizes throad and significantly reduces the effect of palliatives. Maintain optimal roadbed conditions.

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Page 35

Works Cited

Bolander, P., Yamada, A. (November 1999). "Dust Palliative Selection and AppliesGuide." United Department of Agriculture, Forest Service, Technology and Develo]Program. San Dimas Technology and Development Center, San Dimas, California.

Dona Ana County, New Mexico. (2000) "Suggested Best Available Control Measm(BACM) for Reducing Windblown Dust from Manrnade Sources in Dona Ana ComReport.

Environment Australia (1998). "Dust Control Best Practices Environmental Managiin Mining." Australia Government, Department of the Environment and Heritage.www.deh.gov.au/industry/industry-performance/minerals/booklets/dust/dustl.html

Gaffney, P., Shimp D. (1997). "Improving PM10 Emission Inventories." Report toCalifornia Air Resources Board, Technical Support Division.

http://72.14.207.104/search?q=cache:FCsvQJI8jCwJ:www-personal.ksu.edu/~sstevens/Du... 11/3/2005

Introduction- Paae 46 of 111

Gambatese. John A.. James. David E. (2001). "Water Suppression Using Truck-MoWater Stra> Systems." Journal of Construction Engineering and Management V. 13

Gebhart. D.L.. Demght. M.L.. Grau. R.H.. (1999). "Dust Control and TechnologySelection Ke>." U.S. Army Construction Engineering Research Laboratory, LandManagement Laboratory. Resource Mitigation and Protection Division; and the U.SArmy Engineer Waterways Experiment Station. Pavements Division.

Haroian. Rose, and Best Practices Team (2003). "Haul Road Dust Suppression, KejIssues and Solution." Powder River Coal Company.

Rosbury. K.D.. Zimmer. R.A. (1983). "Cost-Effectiveness of Dust Controls Used 01Unpaved Haul Roads, Volume 1: Results. Analysis, and Conclusions/' PEDCoEnvironmental. Inc. U.S. Bureau of Mines.

Sanders. T. Addo. J.Q.. Arimello. A.. Heiden. W.F. (1997). "Relative EffectivenessRoad Dust Suppressants." Journal of Transportation Engineering September/Octet1997. p 393-397.

Skorseth. K . Selim. A.A (2000). Gravel Road Maintenance and Design Manual. SoDakota Local Transportation Assistance Program. U.S. Department of TransportaticFederal Highway Administration.

Thompson R.J.. Yisser. AT. (2002). "Benchmarking Management of Fugitive DustEmissions From Surface-Mine Haul Roads." Transaction of the Institute of MiningMetallurgy. 111/April, pp A2S-A35.

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III. Dust Suppression - Selection Guides

The information supplied throughout this section is intended to provide a comresource for the reader, so as to serve as a starting point for a discussion of vaifeatures and applications of dust suppressants. The data are not necessarilycomprehensive or complete. It is the user's responsibility to thoroughly researand compare products and vendors to determine which can provide high qualiresults and services. Vendors are not equally reliable, or comparable, relative !

timeliness, price or their adherence to recommended application procedures.

It is also the user's responsibility to determine the extent of environmental ini]associated with a given product or application procedure. A vendor's claim oftoxicity should not be considered rigorous proof. As a rule, there is a lack ofdetailed studies on dust suppressant effectiveness and their impact on theenvironment and human health (Frazer, 2003).

It is not the intent of this document to endorse any product or vendor and anyhave been referenced were cited only because of their willingness to providepublished information.

TABLE 3.1 DUST SUPPRESSION PRODUCTS, is a compilation of known proccategories and types, as well as contacts where more information on the product canlocated.

Selection of a dust control product should include a consideration of the manufactuirecommended application procedure. Many times a product is not selected if it requi

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extensive application procedures that under the normal operations of a coal mine caibe performed. Examples of such procedures include extensive road preparation causcessation of operations and/or a prolonged curing time.

Additional selection criteria for dust palliatives should include how the product willperform under high traffic volume and weight, site specific weather conditions, lengtime the product will be effective, how it works on different types of aggregates,effectiveness on steep slopes, and in extreme temperatures, and other criteria depemon individual needs.

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Page 39

Suppressant

Type

Suppressant

Category

Bentonite

Product NAME

Bio Cal 300-1

Table 3.1 Dust Suppression ProductsManufacturer or Primary

Distributor

Central Oregon Bentonite

Regional DistributorPhone

number

541-477

Bentonite

Clay Additives

Pelbon American Colloid Co.800-426

847-392

Bentonite Volclay American Colloid Co. 708-392

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Electro-

chemical

Organic

colloids

Montmorillonite

Enzymes

Enzymes

Enzymes

Enzymes

Ionic

Sulfonated Oils

Sulfonated Oils

Sulfonated Oils

Sulfonated Oils

modified

polysaccaride

Stabilite

Bio Cat 300-1

EMCSQUARED

Perma-Zyme

11X

UBIXNo. 0010

Terrastone

CBR Plus

Condor SS

SA-44 System

Settler

Dust Stop

Soil Stabilization Produces

Soil Stabilization Products Co..

Inc

Soil Stabilization Products Co.,

Inc

The Charbon Group. Inc.

Enzymes Plus, Div of Anderson

Affiliates

Morrhead Group

CBR Plus, Inc. (Canada)

Earth Sciences Products Corp.

Dallas Roadway Products, Inc.

Mantex

Cypher USA

800-523

800-523

800-523

714-593

800-444

831-684

604-684

503-678

800-317

800-527

615-365

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Suppressant

Type

Suppressant

Category

Lignosulfonate

Lignosulfonate

Lignosulfonate

Product NAME

generic

CalBinder

DC-22

Manufacturer or Primary

Distributor

Table 3.1 Dust Suppression Products

Regional Distributor

California-Fresno Oil Co.

Dallas Roadway Products, Inc.

Phone

number

209-486

800-317

Lignosulfonate DC-9112 GE Water Technologies GE Betz Inc.605-642

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Organic Non-

Petroleum

Lignosulfonate

Lignosulfonate

Lignosulfonate

Lignosulfonate

Molasses/Sugar

Beet

Dustac

Dustac-100

Polybinder

RB Ultra Plus

Dust Down

Tall Oil Emulsion Dust Control E

Georgia Pacific West, Inc.

Georgia Pacific West, Inc.

Jim Good Marketing

Roadbind America Inc.

Amalgamated Sugar Co.

Pacific Chemicals, Inc/ Lyman

Dust Control

360-733

360-733

805-746

888-488

208-733

604-828

800-952

Tall Oil Emulsion Dustrol Ex

Tall Oil Emulsion Road Oyl

Dust ControlVegetable Oils

Vegetable Oils

Agent SS

Soapstock

Pacific Chemicals, Inc/ Lyman

Dust Control

ArrMaz Custom Chemicals, Inc.

Winter Haven FL

Greeenland Corp.

Kansas Soybean Association

Indiana Soybean Association

Schommer & Sons

Portland, Oregon

604-828

800-952

863-293

888-682

800-328

800-735

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Suppressant

Type

Suppressant

Category

Asphalt Emulsion CSS-1

Cutback

Dust Oil/Dust

Fluids

Dust Oil/Dust

Fluids

Product NAME

MC-70

Duo Prime Oil

EnviroKleen

Manufacturer or Primary

Distributor

Talble 3.1 Dust Suppression Products

Regional Distributor

Any major asphalt supplier

Any major asphalt supplier

Lyondell Petrochemical

Midwest Industrial Supply, Inc.

Phone

number

800-423

800-321

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Organic

Petroleum

Dust Oil/Dust

Fluids

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Modified Asphalt

Emulsion

Fuel Oil

Asphotac

Cohere*

DOPE-30

Penetrating

Emulsion

Primer (PEP)

Pennz

Suppress-D

Petro Tac

Road Pro

Sandstill

Pacific Northern Industrial Fuels

Actin Inc. East Chicago, Ind

Witco Corp. Chandler AZ

Morgan Emultech, Inc.

Keck Asphalt Co

American Refining Group

Sytech Products Toledo OH

Midwest Industrial Supply

Energy Systems Associates

EnVirotech Services

Inc Greeley, CO

206-284

219-397

800-494

530-241

909-829

814-368

307-369

800-537

800-321

703-503

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Suppressant Suppressant

Type Category

wetting additive

wetting additive

wetting additive

Product NAME

aklyphenol

ethoxylates

Haul Road Dust

Control

TerraBond

Water Wetter

Manufacturer or Primary

Distributor

BASF Chemical Division, Ml.

Olive, NJ

Midwest Industrial Supply, Inc.

TerraBond Industries-Fluid

Sciences, LLC

Table 3.1 Dust Suppression Products

Regional Distributor

Fairmont Supply Co

Green River, WY

Phone

number

800-543

307-875

888-356

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Surfactant

wetting additive

with both ionic

and anionic

properties

wetting additive

with both ionic

and anionic

properties

wetting additive

with both ionic

and anionic

properties

wetting additive,

latex based

sealant

Chem-Loc 101

Chem-Loc 102

Chem-Loc 411

DusTreat

DC9136

Golden West Industries Heber

City, UT

Golden West Industries Heber

City, UT

Golden West Industries Heber

City, LIT

GE Beu, GE Water Technology

Golden West

Industries, Wright,

Wyoming

Golden West

Industries, Wright,

Wyoming

Golden West

Industries, Wright,

Wyoming

800-321

800-321

800-321

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Suppressant

Type

Suppressant

Category

Acrylic co-

polymer

Acrylic co-

polymer

Combination of

Polymers

Product NAME

Dust Buster -

HR51

Envirotac II

Top Shield

Manufacturer or Primary

Distributor

Table 3.1 Dust Suppression Products

Regional Distributor

Midwest Industrial Supply

Environmental Products and

Applications, Inc.

Base Seal Internationa, Inc.

Fairmont Supply Co

Green River WY

Phone

number

307-875

888-674

800-729

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DusiShieldcopolymer

polymer emulsion DirtGlue

polymer emulsion Soiltac

polymer emulsion

Polyvinyl Acetate Aerospray 70A Cytec Industries

Polyvinyl Acetate Soil Master WR

Soil-LOC. Inc. Scottsdale, AZ

DirtGlue Enterprises

Soilworks, LLC Gilbert AZ

TerraBond Dust TerraBond Industries-Fluid

Cap Sciences, LLC

Environmental Soil Systems,

Inc.

Synthetic

Polymer

Emulsions

Vinyl Acrylic

Vinyl Acrylic

Vinyl Acrylic

Vinyl Acrylic

Vinyl Acrylic

Earthbound L

ECO-110

Liquid Dust

Control

Marloc

Earth Chem Inc.

Chem-crete

Enviroseal Corp.

Reclamarc Corp.

PolyPavement PolyPavement Company

Vinyl Acrylic Soil Seal Soil Stabilization

888-828

888-606

800-545

888-356

800-835

800-368

970-223

972-234

561-969

323-954

800-523

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Suppressant

Type

Suppressant

CategoryProduct NAME

Table 3.1 Dust Suppression ProductsManufacturer or Primary _ Phone

DistributorRegional Distributor

Vinyl Acrylic Soil Sement Midwest Industrial Supply, Inc.

number

800-321

800-815

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Vinyl Acrylic Soiloc-D Hercules Environmental770-303

Vinyl AcrylicTerraBond

PolySeal

TerraBond Industries-Fluid

Sciences, LLC888-356

Vinyl Acrylic Top Seal Soils Control International 817-526

polyacrylamides

combined with

super absorbents

Tri-PAM US Marine Corps970-330

908-464

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Suppressant

Type

Suppressant

Category

blend of calcium

chloride and

magnesium

chloride

calcium chloride

Product NAME

Calcium

Table 3.1 Dust Suppression ProductsManufacturer or Primary _ _. .. Phone

DistributorRegional Distributor

Dust Fyghter Midwest Industrial Supply

General Chemical

number

800-321

800-668

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Water

absorbing

calcium chloride

calcium chloride

calcium chloride

magnesium

chloride

magnesium

chloride

magnesium

chloride

magnesium

chloride

Magnesium

chloride (90%)

and 10%

surfactant

(ethoxylated nonly

phenol)

Magnesium

chloride and

proprietary corn

based additive

sodium chloride

sodium chloride

cmoriae liquid

generic

Dowflake

Liquidow

Chlor-tex

DustGard

Dust-Off

magnesium

chloride

Dust Eliminator Brody Chemical

Dow Chemical

Dow Chemical

Soil-Tec

North American Salt Company

Cargill Salt

Oxford, Inc.

Moyie Springs, ID

Caliber

DCA2000Glacial Technologies

Dust Busters, Evanston

,WY

Dust Busters, Evanston

,WY

Brody Chemical-Casper

WY

EnVirotech Services

Inc Greeley, CO

(multiple dust control

products)

208-267

800-447

702-873

307-789

800-553

307-789

800-488

IMC Salt IMC Salt

Morton Salt Morton International

800-369

800-323

312-807

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TABLE 3.2 DUST SUPPRESSION APPLICATIONS GUIDE, is a product selectool, compiled from published sources. This particular guide assembles products ingeneral categories with the addition of application guidelines, environmental issues,application notes, limitations and attributes where known. The reader again should tcautioned that the table cannot be considered complete or comprehensive. It is prob;that there are more substantial differences within a product category than is implied

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me

Since new products are continually being developed, the information compiled in T;

3.2 is incomplete from that perspective as well. Users are encouraged to work withvendors in testing new products... .and just as importantly, in sharing the results.[Detailed case studies w ith less proprietary data are needed.

40

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Page 47

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM1 0

effectiveness

The author cannot

verify that all

levels listed are

time averaged;

the method

preferred by MRI

for Us 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

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

Electro-chemicalEnzymes or

Sulfonaled Oils

low; 39% after one

week and 0% after

1 1 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

Organic colloidsmodified

polysaccharidebiodegradable

41

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Introduction- Page 60 of 111

Page 48

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM ,.

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

Dust Oil/Dust

Fluids85% initial

claimed non

hazardous but

with all petroleum

based products

(here is the

potential for

hydrocarbon

contamination.

.46 gal/sq yd

42

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Introduction- Page 61 of 111

Page 49

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

P M W

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

Organic

Petroleum

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 f'

stabilized road

and rolling

43

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Introduction- Page62of 111

Page 50

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM „

effectiveness

The author cannot

verify thai 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

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

insiru, compac1

44

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Introduction- Page 63 of 111

Page 51

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM ,.

effectiveness

The author cannot

verify that alllevels listed are

time averaged;the method

preferred by MRIfor its ability to

show true

effectiveness.

Environmental

Impact

Recommended

application rate

(general vendorrecommendations -

documentation of

effectiveness on

haul roads is often

inadequate)

Site

preparation

and or

maintenance

needed

Organic Non-

petroleum

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

Tall Oil Emulsion

claimed to be

suitable for

environmentally

sensitive areasbut mostly

unknown

.3 to 1 gal per sq yd at

1:4 dilution rate

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Introduction- Page 64 of.l 11

Page 52

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM1 0

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

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 mo

dependant on

primary

suppression

agent and not

surfactant

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Introduction- Page 65 of 111

46

Page 53

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM „

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

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

hazardoussite specific

scarifying and

grading and

mixed insitu ai

compacted

followed by

topical

application

for extreme

protection the

product needs'

be mixed insiti

polyacrylamidce

s combination

with super

absorbents

reduced dust by 80-

90% at helicopter

landing sites in the

desert

none listed 1 Ib for every 150ft.

product is

applied with a

fertilizer

spreader then

raked and

saturated with

water at a rate

I gallon per 5

sq/ft. Then

topped with an

emulsion

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47

Page 54

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM „

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

Synthetic

Polymer

Emulsions polymer

emulsion

environmentally

safe and

biodegradable no

known water

quality or plant

impacts but needs

product specific

analysis

1 gal undiluted per 50

sqft

May require

specialized

equipment for

mixing in with

soil if not appli

topically

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Introduction- Page 67 of 111

48

Page 55

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM „

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

Vinyl Acrylic

80% 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 anc

roll again grad'

top 3-6 inches

soil. Best whei

applied to a

moist surface

and optimal so

moisture at

least one

product does n

recommend pn

wetting

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Introduction- Page 68 of 111

49

Page 56

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM „

effectiveness

The author cannot

verify that all

levels listed are

time averaged;

the method

preferred by MRI

for its ability to

show true

effectiveness.

EnvironmentalImpact

Recommended

application rate

(general vendor

recommendations -

documentation of

effectiveness on

haul roads is often

inadequate)

Site

preparation

and or

maintenance

needed

calcium chloride less than MgCl

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

ChJoride.

.4 gal/sq yd or

can be topical!

sprayed or

mixed in place

(requires

scarifying)

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Introduction- Page 69 of 111

50

Page 57

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

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

Water absorbing calcium chloride

(Hake)

More

deliquescence than

MgCl 2,

up to 98% for 1-5

days

All chlorides pose

a potential hazard

to offsite plants

after a heavy

rainfall, same as

liquid CaCl 2.

1.5% by weight of

aggregate

tightly blade ai

pre-wet

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Introduction- Page 70 of. 111

51

Page 58

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

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

magnesium

chloridegenerally 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 rales vary

by road type with

gravel the lowest per

sq yd and clay the

highest

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Introduction- Page 71 of 111

52

Page 59

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM10

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

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

needed site

specific

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Introduction- Page 72 of 111

53

Page 60

TABLE 3.2 DUST SUPPRESSANT APPLICATIONS G

Suppressant

Type

Suppressant

Category

PM „

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

The above list OIK! all oilier materials supplied throughout ihis document are intended to prc>vide a convenient source of infi

starling point for a discussion of various features and applications but the Jala is not necessarily fully comprehensive or <

thoroughly research and compare products and vendors to determine which can provide high quality results and services. V

comparable relative to timeliness, priee and their adherence to recommended application procedures. It is not the intent of I

and any that have been referenced were cited because of their willingness to prov ide information only.

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

BOD Biochemical Oxygen Demand is a measure of the amount ofbiodegradeable organic material present in a sample of

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 Plait,

Thompson, R.J. and A. T. Visser 2002. Benchmarking and management of fugitive dust emissions from surface mine haul i

Gebhart, Dick, M. Denight, and R. Grau. 1999. Dust Control Guidance and Technology Selection Key, US Army Construct

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. Rest

Cowherd.C. Jr. et a!., 1988. Control of Open Fugitive Dust Sources, EPA-450/3-88-008, US.EPA, Research Triangle Park,

Muleski, G. E.,et al., 1984. Extended Evai of Unnavetl Road Dust Suppressants in the Iron and Steel Industry, EPA-600^

Cowherd.C. Jr. and J. S. Kinnsey. 1986. Indentiftraiion, Assessment and Control of Fugitive Dust Paniculate Emissions, E

Muleski, G.E. and C. Cowherd, Jr., 1986. Evaluation of the Effectiveness of Chemical Dust Suppressants on Unpaved Roa

Gillies, et al. 1999. Long Term Efficiencies of Dust Suppression to Reduce PM 10 Emissions Fn

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Introduction- Page 73 of 111

54

Page 61

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

Down time for example is a substantial cost that undoubtedly prohibits the icertain suppressants but is difficult to measure. Actual costs per mine needcalculated and used instead. Down time estimates for delays on a main rail-line for coal trains was $1 million per hour (UP: Oct 2, 1998, Perkins, Wyo

The cost and amount of road maintenance needed, such as grading, and compactingalso estimates, ascertained from the 2004 USFS Cost Estimating Guide for RoadConstruction. The USFS estimates were doubled for use on wider haul roads. Thefrequency of the maintenance required for various suppressant types is generallyunknown, and is always situationally dependant. The figures provided are adjustmeimade to data supplied by Sanders, 1997. The suppressant tested with the lowestaggregate loss was lignosulfonate. The difference in aggregate loss compared tolignosulfonate was calculated as a percentage and this adjustment ratio used to estinthe need for road maintenance. CaCl 2 for example was estimated to need 148%blading and related road maintenance than lignosulfonate based on Sanders' finding148% more aggregate loss.

The worksheet is intended to help the user recognize some of the costs beyond inititapplication. Other costs that may have been overlooked for a given site or product acan be added by users. Users are referred to the USFS publication, Bolander et al.(lDust Palliative Selection and Application Guide (pp. 13-14) for additional costingworksheets.

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Introduction- Page 74 of 111

It is apparent that more detailed records are needed in order to better ascertain the cceffectiveness of a given product or application method. Application rates for exampare an important factor in procuct effectiveness, as is the frequency of repeatapplications, yet most of the information supplied by vendors is in ranges so wide a:be unusable. Similar!). more detailed reporting of water usage would assist in thedetermination of water's effectiveness and cost.

55

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Introduction- Page 75 of 111

56

Page 63

A B C

1 Table 3.3 DUST SUPPRESSION ON MINE HAUL ROADS -

Suppressant Type water water absorbing

Suppressant category water CaCl , flat

3

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Introduction- Page 76 of. l l l

Product Examples many

examples have proprietary ingredients and varying application

recommendations that may enhance peformance beyond general

category product

(mi = mile. Lignin'=Lignosulfonate, ctgg' = aggregate, $0-intential

illustration of no data)

Water

Cost per undiluted unit (gal, lon.etc.)

Dilution rate

.02/gal

(in place) USFS

0.30/gal $ 2

(Sanders) (ve

application rate of diluted mixture

7

8 amount of undiluted product/mile (gal, or Ibs)

9 Product cost per sq yd

10 Water portion of mixture in gal/mi

11 initial app Product cost per mile

12 initial app pre wetting/mi (USFS 2004, vendor) 10,000 gal/mi

13 initial app water portion of mixture (gal x .02/gal) USFS

14 surfactant (wetting additive) $85/10000gal

15 initial app scarification/mi (USFS.2004) 1730/mi

16 initial app blading/mi (USFS.2004) 680/mi

17 initial appl mix in place (USFS,2004)(blade rate x 2) 1760/mi

18 initial app rolling/compacting (if separate event) 860/mi

19 initial 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.2021 INITIAL APPLICATION SUBTOTAL (sum of rows 11-20)

10000 gal/mile

(Vendor)

.4gal/sq yd

(USFS)

1.9

(US

10000

$200

$200

$85

$680

9293

$0.0396

18867

$2,788

$200

$377

$160

$680

$1,165 $4,206

57

Page 64

Suppressant Type

A B C

Table 3.3 DUST SUPPRESSION ON MINE HAUL ROADS

water water absorbing

Suppressant category CaCI , flat

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Introduction- Page 77 of 111

I si reapplicalion (50% initial product rate but full cost of app) USDA and

product vendors

2nd re application (repeat of 1st reapplication)

3rd reapplication (see North Carolina Div of Air Q)

25 4th reapplication

26 5th reapplication

6th reapplication

Annual Maintenance blading (USFS,2004) $680/mi x 52 weeks/yr

(cost shown is once/wk/mi for Lignin rated lowest in agg1 loss by

Sanders, 1997 (Others adjusted by maintenance ratiorrow 32)

222324

27

28

29

31

32333435

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)

Maintenance water cost/mile annually (USFS) Uses Row

30 29 estimated water use levels x $200/IOOOOgal

Maintenance aggregate replacement (Sanders 1997. Modified for haul

trucks, 120' haul road and aggregate cost in place of $11.57/ton)

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). Rake CaCI

based on mine engineer performance evaluation

Intangibles

surfactant $85/10000gal of water (if used)

suppressant at 1% solution lOOgal/lOOOOgal tanker ($30)

$0

$208,488

$2,812

$2,812

$2,812

$70,720 $52,374

24528000 12264000

$490,560 $245,280

$1,831,610 $1,356,458

200.00% 148.12%

$0

•5*: TOTAL annual cost per mile application and maintenance

$36,792

$2,602,543 $1,703,544

58

Page 65

Suppressant Type

A B C

Table 3.3 DUST SUPPRESSION ON MINE HAUL ROADS

water water absorbing

Suppressant category CaCI , Hal

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Introduction- Page 78 of 111

33738 Sources:

39 USFS Cosl Estimating Guide for Road Construction 2004

40 USDA FS Dust Palliative Selection and Application Guide

41 Sanders, Thomas el al. 1997. Relative Effectiveness of Road Dust Suppressants

Average haul truck = 550,000lbs(equal to 100 vehicles) 216 haul

trucks per day (9x24) X 3.6 to adjust for 120' road. Aggregate

replacement $} 1,57/ton for crushed rock in place (adjust for scoria as

42 known)

43 Thompson, R.J and A.T.Visser. 2002. Benchmarking and management of fugitive dust emissions from surface mine haul roads.

44 Rosbury, K.D., and R. A. Zimmer. 1983. Cost Effectiveness of Dust Controls Used on Unpaved Haul Roads, PEDCO Environmental, Inc., US Bureau ofH

45 North Carolina Dept of Env and Nat Resources Div of Air Quality. 2003. Economic Analysis ofParticulatesfrom Fugitive Dust Emissions Sources

46 vendors (product vendors and specific mine information (anon1)

59

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60

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Introduction- Page 80 of 111

Page 67

APPENDICES

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61

Page 68

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Introduction- Page 82 of 111

62

Page 69

Appendix A:

Dust Suppression Survey and Results

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63

«IA ~Tf\

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Introduction- Page 84 of 111

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64

Page 71

Dust Suppression Survey (Results)

The following inquiry will assist the researcher in compiling a recommendatiot"best practices" for dust abatement on mine haul roads. Although the results wl

tabulated, your name or company will not be associated with your response

1. Please indicate your primary chemical dust suppressant

MgCl 2 (3), CaCl 2 (1), PennzSuppress (1)2. Please use the following criteria to explain why you use the Primary product youselected in Ql. 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 vendo_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 employi_3 in addition to suppressing dust, the product seems to improve or main

the road surface drivability and/or slows breakdown and need for g_2 requires minimal staff training to adequately apply_1 (your criteria)_Viem/er maintains automated system

(your criteria)(your criteria)

4. Do you currently use a surfactant to improve the efficiency of the water andAyour primary suppressant? _1 yes 4 no

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ii yes junemutc iiu (t) tproaucij

5. A few mines no longer use a surfactant but use a very diluted application of tprimary suppressant instead. Please comment on your mine's use of either;surfactant or a very diluted product with general watering:

-lOOOgal ofMgCl }/45,OOOgal 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 MgCl 2 with general watering in thefuti

6. Would you recommend your primary product (by cost and performance) toused by other mines for haul road dust suppression? Explain:

-MgCl j- Yes. low cost-MgCl i- Yes, when property applied, and minimal blading after*product provides effective low cost suppression compared to alter,-Cad 2- Cost effective with good results-PennzSuppress- Depends on the mine, cost is prohibitive. Howevdealer support and maintenance is critical to our operation.-MgCl 2- Cheapest available product that meets the DEQ/AQDrequirements.

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

-No problem with MgCl 2- Issue is maintenance and upkeep ofroads.- Product (CaCl i)is brought in by railroad into Gillette. Railroinot put a priority on locating RR cars so vendor can off-load procSometimes, the RR cars \v /product sit in the yard for a week befoivendor can access them.- MgCl i- Educating the workforce that unnecessary grading oftrapidly reduces the effectiveness of the treatments. Secondary cotavailability of the product as more industries move to use it in thecontinuing drought.- Spillage from haul trucks covers the chemical and makes it i

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8. Have you tried other road dust suppression products that you were unsatisfie<with? Which ones and why?

- Tried emulsified tree resin, stuck to vehicle parts causing paint i- EMC 2 did not work at all-Unichem

9. If you have discontinued the use of a product which performed well pleaseexplain here:

- MgCl 2, expensive to have shipped to the mine. Not simple orautomated for us to use. Contractors don 't want to use their tankbecause of fear of corrosive behavior.

10. Please rank the following in the order that presents the biggest challenges tosuppression at your coal mine. (1 being the highest, 5 being the lowest (rank on6)). To determine rank, average scores were calculated. Items ranked #1 = .points, #2 = 4 points, #3 = 3 points, #4 = 2 points, #5 = 1 point, unranked = (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 MgClranking of challenges Other issues were selected twice, and in both instances the isswas ranked of highest importance for that mine. Overall the Other category ranked 1for fourth.

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Appendix B:

Dust Control Plan and Self Inspection Checklists

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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 ahedeveloping a dust prevention and control plan as follows:

1. Identify all potential fugitive dust emission sources.

• Start with a facility sile plan map.Record all paved haul roads, unpaved haul roads, stockpiles, matertransfer points, material conveyances, parking lots, staging areas, aother open areas subject to wind erosion.Indicate prevailing wind direction on your map.

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• Study daily traffic volumesDetermine whether roads and open areas are used frequently oroccasionally. Consider daily routine modifications that will reducein some areas or eliminate it altogether

2. Assign dust control methods.

Determine the appropriate dust control method for each sources id<from your facility. If desired, color -code your map to indicate whicontrol method to apply where.

3. Determine frequency pf application.

For each source and each control method identified, determine houfrequently dust control treatments should be applied. Develop a SeInspection Checklist to record the scheduled applications. (See belc

4. Record all dust control activities.

It is a good practice to record your dust control activities on yourchecklist, along with the daily weather information, such as averagspeed and direction, temperature, rainfall, etc. Recording the infornwill 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 tensure that the measures taken are adequately controlling fugitive {

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Self-Inspection Checklist

Use a self-inspection checklist to help incorporate the routine tasks of fugitive dustcontrol into your daily schedule. The checklist serves as a job reminder on a daily b;

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and as a record of your efforts to keep dust problems to a minimum. You can identiproblem areas before they get out of hand, and anticipate adjustments for seasonalchanges or unforeseen circumstances.

The sample checklists on the following pages can be used to document dust controlmethods as well as weather conditions. It is recommended that you use a checklist f<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 covere-

Monitoring of Control Efforts Roads monitored daily

Special Considerations: • Traffic limited on haul ro

placing product near t)of facility

• Speed limit of 10 miles pi

on facility grounds

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Example Self-Inspection Checklist: Fugitive Dust Control Method Log

Fugitive Dust Source: Unpaved Haul Roads

Date Time Control Method Comm4-1-02 7am Magnesium Chloride Allhai

applied facility6-1-02 7am Magnesium Chloride Entram

applied facilityonly

8-1-02 7am Magnesium Chloride Allhaiapplied facility

10-1-02 - See weather log12-1-02 - See weather log

Self-Inspection Checklist: Weather Loged/ Amt. of Rainfall Comra

0.10 inch \c

0.0 inch \c

0.05 inch \c

0.0 inch \c

Best Management Practices: Fugitive Dust Control Methods

To control fugitive dust emissions, the Idaho Department of Environment Quality (1and representatives of the rock crushing industry have developed Best ManagementPractices (BMPs) for the following fugitive dust generating sources:

Paved public roads

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Date

10-2-02

10-8-02

10-15-02

10-22-02

Temperature

55 F (high)

50 F (high)

56 F (high)

52 F (high)

WindDirect

5 mph

8mph

8 mph

7 mph

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Unpaved haul roadsConveyor transfer points and screening operationsCrushers and grinding millsStockpiles

Although directed at the rock crushing industry in particular, many of these practiceapplicable to mining and mineral processing facilities, sand and gravel operations, aconcrete asphalts batch plants as well. The recommendations specific to haul roadsfollow:

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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 sigithey 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 notsaturate the surface of the unpaved haul road and cause trackout. If runoff isor cannot be controlled, try applying gravel to the surface of the unpaved hiroad 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

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(Ihompson and Visser)

73

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Page 80

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The following chart by Thompson and Visser (2002) provides additional comparisothe perceived performance of several dust palliatives relative to plasticity, slope, travolumes and applications. ("Benchmarking of Fugitive Dust Emissions from SurfacMine Haul Roads" p. A29.)

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Appendix D:

Dust Palliative Selection Matrix

(Bolander and Yamada, USFS)

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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 Palli;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 suppresselection based on use/traffic volumes, surface material, and climatic conditions.

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Notts:

(1) May require higher or more frequent application rates, especially with high track 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)

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Primary Author Authors Title YearName of Journal or

Publication

Arizona Dept of

Environmental

Quality

Arizona Department of Environmental Quality

Air quality exceptional and natural events

policy PM |0 best available control measures

2001

Associated Press

InternationalEPA Watching Dust From Mines, Roads 2003

Associated Press State and

Local Wire

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Australia Dept of

the Environment

and Heritage

Dust Control, Best Practices Environmental

Management in Mining, Australia98

Sustainable Industry;

Sustainable Minerals

Axetell, Ken, Jr.

Banard, W.R.

Barnard, W.

Barnard, W.R.

Baxter, Roberta

Becker, D.C.

Beggs,T.W.

BerthekX, C.

Blackwood, T. R.

Blanc, T.R.

Survey of Fugitive Dust from Coal Mines

Development of Emission Factors for

Stensland, G.J; Unpaved Roads: Implications of the New

Gate, D.F. PM 10 regulations. Transactions, PM

Implementation of Standards

Improved fugitive dust PM |0 emis<

estimates for trends

Development of emission factors for unpaved

roads

Arrest that Fugitive Dust!

Quantifying the Environmental Impact of

Paniculate Deposition from Dry Unpaved

Roadways

User's Guide: Fugitive Dust Control

Demonstration Studies

Gravel Loss characterization and Innovative

Carpentier, A. Preservation Treatments of Gravel Roads:

Saskatchewan, Canada

Assessment of Road Carpet for Control of

Fugitive Emissions from Unpaved Roads

Lingosulfonate Stabilization

78 EPA 6801 4489

88Air Pollution Control

Association

Transactions, Standards and

92 Non-Traditional Particulate

Source Controls

Transactions, PM88

Implementation Standards

2003 Erosion Control

unpublished Master's thesis

Iowa State University

85 EPA

2003Transportation Research

Record

79 EPA

Proceedings - ARTBA-NAC

Conference Local

Transportation

83

Page 90

Primary Author Authors

Bolander, P.

Bolander, P.,

Yamada, A.

Chitwood, L.;

Steele, H.M.;

Title

Lessons learned from the failure of a

bituminous surface treatment in central

Oregon

Dust Palliative Selection and Application

Guide

Year

99

Name of Journal or

Publication

Transportation Research

Record

Forest Service Technology

and Development Program

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Bolander, Peter

Bolander, Peter

Games, D. H.

Carter, R.

A Guideline to Liquid Spray Applications for

Erosion Contol, Dust Abatement, and

Tackifiers

Chemical Additives for Dust Control - What

We've Used and What We've Learned

The control of fugitive emissions using

windscreens

Cut costs by controlling dust; heavy haul-

road dust can stir up haulage and

maintenance problems

96 U.S. Forest Service

96

82

USDA Forest Service,

Portland Oregon

Third Symposium on the

Transfer and Utilization of

Paniculate Control

Technology, Vol IV.

96 Coal Age, vol 104, n 12

Champlin, Robert

L.

Control of Fugitive Dust from mining haul

roads78 EPA

Colbert, W.

Council of Fresno

County

Government

Countess,

Richard

Center for dirt

and gravel road

studies

Natural Systems Approach to preventing

environmental harm from unpaved roads

Overview of Regional Transportation

Planning Agency Process to Identify and

Implement Best Available Control Measures

in Support of the PM ,„ Plan for the San

Joaquin Valley

Methodology for Estimating Fugitive

Windblown and Mechanically Resuspended

Road Dust Emissions Applicable for Regional

Scale Air Quality Monitoring

Transportation Research

Record, v 1, n 18192003

2002

Western Governor's

2001 Association Contract 30203

9

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

84

Page 91

Primary Author Authors

Cowherd, C

Cowherd, C.

Kinsey,J.S.

etal.

r:,,*>nttiar r M

Title

Identification, Assessment and Control of

fugitive dust particulate emissions

Development of Emissions Factors for

Fugitive Dust Sources

Development of Methodology and emission

YearName of Journal or

Publication

86 EPA Report

74 EPA

EPA Office of Air Quality

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Cowherd, C.

Cowherd, C.

Cowherd, C.

cnc

Cuscino, Thomas

Dubyk, S.

Dulla, R.G.

Dunkins, R.

Dyck, R.I

Eaton, R.A;

Engle, David

Englehart, PJ.

EPA

Kuyhendal, W.B.

Withycombe, E

Strokel, I.J.

Gerard, S; Gate,

D.W.

Muleski, G.E.

EC/R Inc. NC

IlllvlliVIJ *UI luglulvuual iwi UK* IkglulMU Ull

pollution study.

Fine Particle Components of PM 10 From

Fugitive Dust Sources

Fugitive Dust Emissions

Profiling Data for open fugitive dust sources

Prepared for US EPA, Emission Factors and

Inventory Group, Office of Air Quality

Planning and Standards

Road Dust Suppressants

Fugitive Dust from Vehicles Traveling on

unpaved roads

Fugitive Dust Control Techniques and

Businesses

Paniculate control measure feasibility

STUDY

Fugitive Dust Background Document and

Technical Information Document for Best

Available Control Measures

Fugitive Dust Emissions From Trucks on

Unpaved Roads

Rating Unsurfaced Roads

Road Maintenance Techniques and Products

Have Made Great Strides

Open fugitive dust PM ,0 control strategies

study

Control Techniques for Paniculate Emissions

from Stationary Sources, Vol I

Planning and Standards

Air &amp; Waste

97 Management Assoc. 1997

Proceeding

96MRI

99 EPA, MRI

Colorado Transportation

89 Information Center, Bulletir

#3

76 EPA

2004 website

97Maricopa Association of

Governments Report

92 EPA

Environ. Sci. Technol. 10,76

1046-1048

88 Army Corps of Eugr.

Forester Communications2004

January/Feburary

80 Study

EPA45038l005a

85

Page 92

Primary Author Authors Title

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World Trade Center Indoor Dust Cleaning Program: Cleaning Contract Scope of Work

A Case Study of Lead Contamination Cleanup Effective at Bunker Hill: Sean Sheldrakeand Marc Stifelman

Basis for Educational Recommendations on Reducing Childhood Lead Exposure:USEPA, Office of Pollution Prevention and Toxics

Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing: USDepartment of Housing and Urban Development

ARC 2005: Assessment, Cleaning & Restoration ofHVAC Systems: National Air DuctCleaners Association

Summary and Assessment of Published Information on Determining Lead Exposures andMitigating Lead Hazards Associated with Dust and Soil in Residential Carpets, Furnitureand Forced Air Ducts: Battelle, Columbus OH for National Program Chemicals Division,USEPA

Bunker Hill House Dust Pilot Final Remedial Effectiveness Report: Terra GraphicEnvironmental Engineering

Wrap Fugitive Dust Handbook: Countess Environmental, Westlake Village, CA

Guidelines for Network Design and Optimum Site Exposure for PA/2.5 and PMjo: USEPA,Office of Air Quality Planning and Standards Research Triangle Park

Dust Suppression on Wyoming's Coal Mine Haul Roads: Temple Stevenson