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One of the most cost-effective and direct means of controlling fugitive dust is using a dry fog
system. The technology isnt new. A 1981 article published in Coal Industry News discussed the
use of dry fog for explosive dust control at Westvaco (paper mills) and Dayton Power & Light.
In that article, Sonic, the developer of the dry fog dust suppression technology, predicted that
this new technology is going to have a major impact on coal handling in the years ahead.
With recognition long overdue, fogging systems were recently declared a best demonstrated
technology (BDT) for coal-handling equipment used with sub bituminous and lignite coals by
the U.S. Environmental Protection Agency (EPA) in 40 CFR Part 60 Standards of Performance
for Coal Preparation and Processing Plants; Final Rule, published October 8, 2009. BDT, as
defined by the EPA, is the most effective commercially available means of treating specific
wastes, in this case, fugitive dust emissions. Public testimony given to the EPA on fogging
systems has confirmed that 29-year-old prediction: Dry fog can be the most cost effective dust
control system available.
The BDT designation was due in part to the supportive testimony by representatives from PRB
coal mines, PRB coal-fired plants, mining associations, Air Utility Group, and various state air
regulators. Representatives from PRB coal mines and power plants testified that fogging systems
have dramatically reduced capital and operating cost while simultaneously increasing dust
control efficiency.
One PRB coal mine presented a detailed cost analysis of competing dust control technologies. Its
study concluded that the total ownership cost of dust scrubbers was 50% more and replacement
bughouses were 400% more expensive than using atomizing fog for dust control over a 30-year
life cycle. Chemical systems are not BDT for sub bituminous and lignite coals and therefore
were not considered in this analysis.
The PRB mine analysis also estimated that bag houses use 2.5 times more energy than dry
foggers.
Fogging Proved Better Than Baghouses
Why did it take regulators so long to recognize the importance of properly managing fugitive
dust in general and the benefits of fogging systems in particular? According to David Gilroy of
Dust Solutions Inc., When the demand for PRB exploded in the early 1990s, PRB mines were
very busy building new facilities and were required to install bag house collection systems as
BDT. Since this rush to build bag houses, there have been many bag house fires and some violent
explosions caused by the inherent properties of PRB coal. Power plants burning PRB coal were
also having the same experiences.
The CSB Investigation Report also found that 18% of all incidents and fatalities involved dust
collectors such as bughouses.
The risk of fires, explosions, and noncompliance has prompted nearly every PRB coal mine and
more than 100 coal-fired power plants to phase out mechanical dust collection in favor of a
fogging system. With dry fog, there is no explosive exhaust stream.
One of the first PRB coal mines to make the switch to dry foggers was Triton Coal (now Black
Thunder). The transition was difficult because regulators required the mine to keep the
mechanical dust collection systems in service until they could demonstrate that the foggers
worked at least as well as the mechanical systems. The foggers proved their value, and, as they
say, the rest is history. Wyoming, the home of PRB coal, eventually permitted fogging systems as
best available control technology (BACT) for PRB coal conveyor transfer points, giving fog
systems a Zero Visible Emission Rating. Today, nearly every PRB mine has a fog system as part
of its dust control strategy.
Word of the success of this new technology at the PRB coal mines trickled into the power
generation industry, especially at plants that were converting to burn PRB coal. PRB coal mines
are concerned about handling the coal from the mine to the freight cars. Coal-fired plants are
concerned about unloading the coal, but theyre even more concerned about storing, handling,
and pulverizing a coal with extremely friable outer layers that dry quickly, which makes more
fines that increase the potential for baghouse fires and dust explosions. They soon became
interested in the potential of fogging.