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Document Brief

July 10, 2008...

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U.S . Environmental Protection Agency J EPA West (Air Docket) , Room 3334 OW tirD .,.D 01T a., I F ,, B l FERN 'V " " -W'"" M ', ,W1301 Constitution Avenue, N .W . Washington, D .C . 2004 PO BOX ,N09 Attn Docket ID No . EPA-HQ-OAR-2008-0260...

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RE 73 Federal Register 22901 (April 28, 2008) Proposed Rule 40 CFR Part 60, Standards of Performance for Coal Preparation Plant s Dear Sir or Madam Western Fuels-Wyoming, Inc . provides the following comments regarding the above proposed rule regarding dust control from coal conveying and crushing facilities . This comment letter is focused solely on the 73 Federal Register 22901 recommendations regarding control of dust during conveyor belt transfers and crushing . We have other concerns with these proposed changes to the Subpart Y regulations, which are addressed by the National Mining Association . These proposed rules will mandate that non-bituminous coal handling facilities must be vented through a stack and be controlled by use of baghouse dust collectors . We have numerous issues with this proposal, as follows ...

Filter Dust Collectors (B aghouses) Pose Unreasonable Fire/Explosion Hazard To require baghouses as dust control for combustible dust sources is unnecessary for dust control, impractical compared to alternatives, and will cause significant safety issues at our operation . The EPA may not be aware that subbituminous Powder River Basin (PRB) coal spontaneously combusts if it accumulates for long periods of time, or if it is exposed to water or oxygen . Since baghouses by design extract dust, and eventually suck it to collection point, where it is recycled back onto the belt, baghouses often have dust accumulations which do not purge from the dust collection ductwork . Therefore baghouses are absolutely the WORST possible dust control option for control of dust at a coal or other facility handling combustible dust . The baghouses accumulate dust, moisture eventually enters the ductwork and baghouse proper, and the baghouses spontaneously combust and eventually may EXPLODE!...

J U L 13 2008...

In our cover letter of July 1, 2008, we submitted comments from six (6) of our coal handling technicians . They succinctly explained the problems they experience first-hand with baghouses in coal handling operations, and their preference for atomizing fog systems . Their number one issue with ba...

Document Keywords

Testimony to the EPA See PRB Coal Mine Testimony to EPA images stories file attachements epa hq oar 2008 0260 0065 dry fork

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Dust Solution Inc., provider of the best dust suppression solutions in the industry.

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