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Bowie Resources, LLC <br />Page 2 <br />12/22/2016 <br />The proposed TR -110 application states that the Daxiom technology will be used to convert coal <br />mine waste to synthetic gas which is then used to generate electrical power or diesel/fuel oil. <br />Although the Bowie No. 2 Mine has four gob piles (coal mine processing waste) permitted and <br />approved, no discussion of utilizing the coal waste permitted under the Bowie No. 2 Mine is <br />included in the TR -110 application. A discussion as to the origin of the coal waste proposed to be <br />utilized in the Daxiom plant (plant) is required. <br />If the coal waste to be utilized in the plant is to originate from a gob pile permitted by BRL and <br />within the Bowie No. 2 Mine approved permit boundary, please provide the Division with a <br />revised section 2.05.3(8) which provides a revised narrative explaining the construction, <br />modification, use, maintenance, removal, and reclamation of the coal mine waste gob pile to be <br />utilized in the plant. <br />The cover page of proposed exhibit 25 of Volume III states that the maximum thru put of each <br />Daxiom plant unit is 72 tons per day of coal mine waste and the plant can run 24 hours a day, 7 <br />days a week. The Division understands that amount of coal mine waste to equate to 360 tons a <br />day (5 units X 72 tons a day) or 131,400 tons of coal mine waste per year. Based on quarterly <br />Gob Pile inspection reports and the currently approved PAP, approximately three million tons of <br />coal mine waste has been placed in the gob piles since 2009. As noted in adequacy comment 2 <br />above, BRL has not stated the origin of the coal mine waste to be utilized in the plant. <br />Currently the approved reclamation plan associated with the gob piles includes filling the area of <br />the gob piles to maximum capacity, grading, suitable material cover, topsoil, and revegetation. <br />If the origin of the coal mine waste is the approved gob piles within the Bowie No. 2 Mine, the <br />approved reclamation plan may be required to be revised. If a revision to the reclamation plan, <br />based on the amount of coal mine waste removed from the gob pile, constitutes a significant <br />change in the reclamation plan a Permit Revision may be required. Please provide to the <br />Division a discussion addressing the amount of any coal mine waste to be removed from any of <br />Gob Pile #1, #2, #3, or #4 to be utilized in the plant. The discussion should include the amount <br />of coal mine waste to be removed chronologically (monthly, quarterly, or yearly). <br />4. The currently approved permit application package (PAP) identifies 10 emission permits issued by <br />the Colorado Air Quality Control Commission. Based on the information submitted with the <br />proposd TR -110, a revised or new emission permit may be required prior to approval. Per Rule <br />2.05.6(1)(a) and (b), the application shall contain a copy of the application for such an emission <br />permit and shall contain a description of the steps to be taken, including copies of the permits or <br />permit applications to comply with other applicable State or Federal air quality laws or <br />regulations. Please provide evidence to the Division that a revised or new emission permit has <br />been issued or applied for in accordance with 2.05.6(1)(a) and (b). <br />