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HomeMy WebLinkAbout20230918_12-Fugitive_Dust_Control Olerud Mine Fugitive Dust Control Plan FUGITIV DUST CONTROL P AN FOR The Quartz Corp, Olerud Mine Spruce Pine, NC Mitchell County 1 Olerud Mine Fugitive Dust Control Plan Table of Contents Narrative 1. Sources of fugitive dust at the Olerud Site Pg. 3 2. Discussion and Description of Controls for each Fugitive Source Pg. 5 3. Schedule Pg. 10 4. Compliance verification Pg. 11 Appendix 1 - Site maps Appendix 2 - Training Materials Appendix 3 - Records &Amendments 2 Olerud Mine Fugitive Dust Control Plan 1. Sources of fugitive dust at the Olerud Mine `%WP" To control the fugitive dust emissions (fugitives) at the site it is important to establish the source of the fugitives, how they are created, what they are, where they are, how they are affected by weather. 15A NCACO2D.0540 Describes fugitive dust emissions as particulate matter that does not pass through a process stack or vent and that is generated within the plant property boundaries form activities such as unloading and loading areas, process areas, stockpile working, plant parking lots, and plant roads. Excess Fugitive dust emissions means: Fugitive dust is visible extending beyond the facilities property line. At the Duncan Mine (site or the site) fugitives are generated by several operations and at several different locations. The known sources of fugitives at the site are as follows: 1.1 Development of Infrastructure for the Site: Drilling and Breaking The drilling and breaking of rock for the construction of suitable haul roads for highway dump trucks to deliver tailing will be needed. Truck Loading Once the rock has been drilled and the larger boulders are broken the rock is loaded into trucks for transportation to the portable crusher on site. Truck Dumping Once the truck arrives at the crusher, the rock is dumped near the crusher hopper so a excavator can reach down and feed the portable crusher to be crushed (sized). Tailings are also transported by truck and must be dumped. Crushing and Conveying The site crushing operation is made up of various crushing equipment and conveyors which crush, size the rock to obtain the proper size. Stockpiling (from belt, loader or truck) The sizing and separating of rock to stockpile materials and maintain the piles for placement on the haul roads as gravel. 3 Olerud Mine Fugitive Dust Control Plan 1.2 Main Activity of Olerud Mine: Mineral Disposal The Olerud site will receive mine overburden consisting of overlaying soils and rock unusable as feed stock for the processing plants and in the industrial stone markets has to be removed from the active mine and disposed of. The overburden materials are inert earth and are delivered to the site in trucks and dumped so the material can be bladed into a slope which is seeded and grassed to stabilize it. The site will also receive mineral tailings which are a byproduct of the crushing, screen, grinding and separation process in the plant and the materials range in size from fine particulate up to gravel size. Materials not shipped from the plants as product become tailings which may be disposed of at the Olerud mine. A goal of<10 acres of exposed tailings will be maintained. If the goal of 10 acres of exposed tailings is exceeded, notification will be submitted to NACDAQ along with information including reason for and length of time expected for the exceeded exposure. Any additional dust suppression measures to be incorporated during this time will also be reported. Grading and Sloping Grading and sloping will be a continuous practice at the Olerud mine as reclamation is concurrent with the placement of tailings. Grading and sloping processes will include the placement of soils in preparation for seeding. Haul Roads To transport materials to the site a number of haul roads will be utilized. 1.3 Other: Nights and Weekends To control dust on nights and weekends, all possible measure will be taken before the end of the last active shift to ensure dust will be controlled. Under unusual conditions, additional staff may be scheduled. 4 olerud Mine Fugitive Dust Control Plan Weather (severe cold, and conditions and high winds) The location of the site and the weather is a factor in controlling fugitives due to extremes. 2. Discussion and Description of Controls for each Fugitive Source Below is a discussion of each of the listed fugitive sources and also a control or controls for those fugitives. This plan in its entirety is performance based and some of the controls described and suggested are known to work well and others are trial solutions that can be employed and tested to prove their effectiveness before they are proven and become a permanent part of this plan. The controls for fugitives at the site are as follows: Drilling and Breaking The drilling and breaking of the rock is performed by machines and the drilling has wet suppression attachments on the drill to prevent fugitive dusts. Breaking is performed by hammering the boulder using a machine and there is no wet suppression application feasible for this practice other than spraying the boulder before the breaking process begins which only coats the outside of the boulder and proves inadequate to control the fugitives. Both drilling and breaking produces fugitives in small amounts that are dispersed locally and do not cross property lines unless carried by wind. During times of high wind or below freezing temperatures the area around the drilling and breaking site shall be sprayed with water and or other wetting or coating agents to prevent wind erosion and cause fugitives. Truck Loading Truck loading in the mine from the shot rock in the development of haul roads is performed by a excavator and because the digging is into a pile, the materials are wet and damp thus eliminating fugitives. The loading of trucks is not seen as a major source of fugitives. Normally fugitives produced will be local to the area but has potential during times of high winds and below freezing temperatures to be swept across property lines_ Care should be used by equipment operators when loading trucks, to allow the materials to flow into the truck and not be dumped high where the 5 Olerud Mine Fugitive Dust Control Plan materials fall into the truck, generating fugitives. During times of high wind or below freezing temperatures the materials being loaded shall be sprayed with water and or other wetting or coating agents to prevent wind erosion and fugitives. Truck Dumping Truck dumping is performed at different locations throughout the site from the mines as out of spec finished product dumping, and the dumping of tailings. Off Road Haul trucks transport the rock to the portable crusher, is dumped near the the crusher hopper so that a excavator can reach down and place rock in the crusher hopper to be crushed (sized). The rock is falls from the bed of the truck on to a small stockpile and if the material was loaded from a wet pile at the mines there will be no fugitive emmisions. During arid periods or times of high wind and extreme cold below freezing temperatures the material may require spraying with water during the dumping process to prevent fugitives. This can be done by dumping against piles and allowing the materials to flow to the ground to be moved to their final placement by other equipment. The dumping of off spec finish product shall be performed at the tailings collection area where it can mix with wet materials and thus prevent fugitives. The dry materials shall be dumped in such a way as to make the materials flow and not fall from the truck. The dumping of tailings is not normally a source of fugitives due to the moisture content of the tailings materials. If the tailings pile is dry on the surface the materials should be mixed during the loading to assure the materials are wet and damp and do not produce fugitives. Materials transported in haul trucks shall be covered at all times during transport. Crushing and Conveying The crushing of the rock will be for road gravel. The crusher are supplied with wet suppression controls such as water bars, sprays and misters and when the controls are maintained and operating properly no fugitive emissions are produced. During arid periods or times of high wind and extreme cold below freezing temperatures crushers may need extra attention as the materials are harder to wet and prevent fugitives. 6 Olerud Mine Fugitive Dust Control Plan 'mod Overburden and Tailings Disposal Any emission problems at the site will be due to overburden and tailings tailings disposal and the associated disposal site. Mineral tailings are a byproduct of the crushing, screen, grinding and separation process in the plant and the materials range in size from fine particulate up to gravel size. Materials not shipped from the plants as product become tailings which are disposed of at the mine site. Some of the tailings are minus 325 (sieve size) mesh materials and although wet when delivered to the disposal site dry and conditions can dry the tailings and they can become fugitives when carried by the wind. During times of extreme cold and high winds the tailings materials have the moisture drawn from them by the cold air and the frozen materials underneath becomes a sheet on which the fine particulates can be conveyed into the air with ease. If the tailings materials can be prevented from becoming air born there are no fugitives. The ambient weather plays a larger role in the fugitives at the site than any other factor. Control of the tailing's disposal area can be accomplished economically with wet suppression and is performed by the use of the water truck. The truck will wet all tailings areas not vegetated and subject to wind erosion. As part of the overall mine plan all brush, trees, stumps etc that needed to be cleared for placement of tailing will be mulch or chipped. This material then can be used as cover on "flat active areas in freezing weather. The tailings area can also be controlled by using a dust suppressant polymer such as "gorilla snot" which when applied forms a crust with the material and prevents the wind erosion and carrying the fugitives into the air where they are swept across property boundaries. The dust suppressant polymer is applied using a hydro seeder which can spray the polymer/water mixture the distance necessary to cover the entire area. Planning is necessary to schedule the treatment of the tailings disposal area so that during cold and windy weather the water and or polymers can be applied before the temperatures prevent the application. Olerud Mine Fugitive Dust Control Plan The site mine plan calls for the placement materials from the bottom proceeding upward and the fill will be placed in lifts and seeded as the site develops. The seeding will be performed in spring and fall (growing seasons) to minimize the exposed areas. Tests involving snow fence like structures will be conducted to see if they will also be possible control. The fence will be made of a mesh that will slow the wind causing the dust particles to fall from the reduced velocities. Similar tests were performed at another mining site in the 1990's and showed promise with the control of fugitives but further testing will be needed to perfect the control Grading and Sloping Grading and sloping is a continuous practice at the site as reclamation is concurrent with tailings disposal. Grading and sloping of topsoil placement in preparation for seeding and is normally performed during the "growing seasons". The grading and sloping shall be followed by seeding within 15 working days and checked for vegetation and vigorous growth after seeding, to assure fugitives are being controlled. Weather (severe cold and high winds) The location of the site and the weather is a factor in controlling fugitives due to extremes. Because we have no control over the weather and its effects on the site proper monitoring of the weather forecast can help in preparing the site before harsh or inclement weather. There is no advantage to wetting the site prior to below freezing weather because the thin air dries out the materials and allows them to become uncontrolled. Wet suppression will not work during arid or high wind days because it also dries out the materials. Proper preparations should be made before inclement weather to assure the fugitives are controlled during the weather event. This may include placement of thin layers of topsoil on finished grade slopes during non-growing seasons. Placement of mulch and keeping the polymers in stock and ready for application and having the manpower to properly apply the controls. 8 Olerud Mine Fugitive Dust Control Plan Haul roads The site has three major haul road to move tailings and general traffic of service and maintenance trucks. Along with those roads, other temporary haul roads will be needed for access the active mine area. The gravel roads will be watered if they are to be used that day and at several intervals during the day. All exits on to paved roads will have mud mats to keep the tailing material off the paved roads. Watering should be performed when the greatest amount of control can be obtained with the smallest amount of water being used. In cold weather months a polymer such as "Durasoil" or another NCDEQ approved road dust suppressant will be placed on the roads. All watering and haul road treatments will be recorded in a log book. As a contingency plan for water tuck breakdowns, contractors are available for backup. Totes of dust suppressant will be maintained in stock for use. 9 Olerud Mine Fugitive Dust Control Plan 3. Schedule Daily Plan On a daily basis, the water truck will be staffed. Each day, conditions will be reviewed and assignments made based on this review. The plan will be communicated to employees and contractors responsible for dust control on a daily basis. Implementation Implementation of a similar plan has already used at another The Quartz Corp mine. Wet suppression is being used on the crusher operations as required as it has been and not fugitive problems have been noted there. As previously discussed, the tailings are being watered, mulch have been used on flat areas of active operations and slopes have been treated with polymers. As areas have been brought to final grade topsoil has been placed and vegetation has been planted. In non-planting seasons, areas where the slope are to proper grade, a layer of soil will be placed to control dust till the next planting season. As part of the dust control plan a third-party weather station will be installed and maintained on site if needed. An alert system for sustainable wind events i.e. 25 miles/per or greater over 2 minutes long will be in place. A text message alert will notify the mine management personal immediately of any exceedance. Checking for effectiveness No plan can work without it being tested, reviewed and graded for effectiveness. This plan shall be upgraded and changed to control fugitives as needed. The changes shall be added to the plan as amendments and the review process and amendments recorded in the plan and approved by the mine manager. This will be performed annually by January 31 and records will be maintained. 10 Olerud Mine Fugitive Dust Control Plan Employee and Contractor Awareness Training N�ftw/ Making employees contractors and others who work at the site aware of the fugitives, how they are produces and how to controls them will greatly help in reducing fugitives at the site. Most fugitives can be controlled by simple steps that will be taught to the employees, contractors and others who work at the site. Training will include but not be limited to: knowledge of fugitives and their sources, visible observation methods and techniques, wet suppression, polymer applications or mulch, proper dumping from trucks, how weather affects fugitives and what steps to take when weather will be an issue. Records will be kept of all training and persons trained will have to sign a document stating they have been trained and are responsible for tier areas. The awareness training will be given annually for all hourly employees and records will be maintained. \low/ 4. Compliance Verification Visual Observation Training (EPA Method 22) Certain Key individuals will be trained in how to identify fugitives using EPA Method 22. The training will include a short lecture covering the different types of visual observation methods and a field exercise. Those taking the training will be listed in the plan as being trained and will sign a sheet acknowledging training was given. The method 22 training will be kept current for the following positions: The Lands and Mines Manager The Mine manager The Environmental Manager Record Keeping Records shall be kept to allow the NC DEQ Division of Air Quality to see the work being done to assure compliance NC DEQ Laws and Regulations and also this plan. Records shall include but not be limited to: 11 Olerud Mine Fugitive Dust Control Plan a. Training records a. Employees 114 J b. Contractors c. Others b. Observations at the site of one per day of operation when wind speeds trigger method 22 observation c. Notification records a. NC DEQ b. Neighbors c. Management d. Control use and how implemented on tailings and haul roads a. What was the control and when implemented b. Maintain daily log of water truck operation b. Maintain record of dust suppression polymer inventory and applications c. Maintain record of seeding d. Any testing of new controls e. Complaints and Dust Events When a dust complaint is received or a significant dust event occurs, an investigation will be conducted and any recommendations for corrective action will be documented. 12 Olerud Mine Fugitive Dust Control Plan Appe'ndix' l 13 Olerud Mine Fugitive Dust Control Plan General (area) Site Map Duncan Mine and Adjacent Land Owners 1095000 1090000 1099000 1099009 10900oo' \ The+I,uay9 DUE dnl tr IIC4ItIi CO 1 ice.T� 0 Id.^pti :II OCC 91 �� ilf 3 11 Y Legend \ 1 ..1 10BW00 109mo 109I000' 1049000 i 1.000 500 0 1,000 Feet THE OUARTT' V 14 Olerud Mine Fugitive Dust Control Plan �- Tailings Disposal Area 109MD- 109e009 wacim 1090000- 1000000 '!Ue UA,..Jo-? UU,:an fjmt L4 WII co ' I r J'• L19a0d U 1U�u,v'n 1,I:N tj yt(s � JcY•'y�' � al J'. I 10950 0 1090000 loom" - 1000000 1,000 500 0 1,000 Feet THE �I QUARTZ' 15 Olerud Mine Fugitive Dust Control Plan Appendix 2 Training Materials Fugitive Dust control Training Outline 1. Discussion of Permit a. Who issues? b. What is says about fugitives and the definitions? c. Authority and duty to comply 2. How are fugitives produced a. Sources at Duncan Mine 3. How fugitives are controlled a. Controls at Duncan Mine 4. How to visually detect and identify fugitives 5. How to react and respond to fugitives discovery 6. New ideas welcomed 7. Record keeping `..� 8. Questions and Answers Method 22 class outline 1. Discussion of test a. Reason for method b. Reason to perform testing at Olerud Mine 2. Overview of method a. Procedure b. Testing rules, durations and other information c. recording of test results 3. How to use method at Olerud Mine 4. Importance of test and recorded results 16 Olerud Mine Fugitive Dust Control Plan Appendix 3 /4006N Records and Amendments 1. Training records 2. Observations at the site 3. Notification records 4. Control use and how implemented 5. Neighbor problems 6. Weather events 7. Notifications of violations 17