The text of the notice says roads totally within the facility property are exempt
from dust control work practice requirements:
“For roadways that do not leave the property (e.g., haul roads at coal mines), the
owner/operator of the coal preparation plant would not have to include such
requirements in the fugitive dust plan because of the particular impracticality of, for
example, paving roadways that are frequently rerouted.”
But the actual language doesn’t clearly communicate this:
(i) The fugitive emissions control plan must address each of the fugitive emissions
sources listed in paragraphs (b)(3)(i)(A) through (C) of this section that are located
at the facility.
....
(B) Roadways associated with and within the same contiguous property as the
coal preparation and processing plant.
Comment submitted by K. Mathews
This is comment on Proposed Rule
Standards of Performance for Coal Preparation and Processing Plants
View Comment
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