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AIR POLLUTION CONTROL DIVISION <br />Field Inspection Report <br />COUNTY NUMBER: 051 SOURCE NUMBER: 0015 <br />DATE OF INSPECTION: 9/11/2012 <br />DATE REPORT SUBMITTED: 2/20/2013, revised 4/4/2013 <br />COMPANY: Mountain Coal Co, LLC — West Elk Mine <br />SITE LOCATION: 5174 Highway 133, Somerset, CO 81434 <br />MAILING ADDRESS: PO Box 591, Somerset, CO 81434 <br />CONTACT PERSON: Kathy Welt — Env Engineer III <br />TELEPHONE NO.: 970-929-2238 <br />SOURCE CLASS: Major [ ] Syn Minor [ X* ] <br />INSPECTOR: Ben Cappa - APCD <br />COUNTY: Gunnison <br />TIME: 8 am <br />PERMIT NO.: 93GU886.XA <br />09GU1382 <br />Minor [ ] 10GU1130 <br />INSPECTION TYPE: Full Compliance Evaluation [ X ] <br />Partial Compliance Evaluation [ ] <br />Complaint Investigation [ ] <br />HOURS: <br />Inspection: 10 Travel & Prep: 12 Report: 26 Total: 48 <br />COMPLIANCE STATUS: IN COMPLIANCE[ ] OUT OF COMPLIANCE [ X ] <br />* At the time of the inspection, the source was still listed in Division records as a synthetic minor facility. The <br />source submitted a Title V application for Greenhouse Gas Emissions on June 29, 2012, and will soon be <br />considered a Title V source. However, the source contends that they are not subject to Title V requirements <br />as they believe the methane emissions from the mine are fugitive and thus not applicable. <br />INSPECTION NARRATIVE <br />On September 11, 2012, Mr. Ben Cappa, Inspector with the CDPHE -Air Pollution Control <br />Division (Division), conducted an announced inspection of the Mountain Coal Company LLC — <br />West Elk Mine ('MCC'), located one mile east of Somerset, CO. Mr. Cappa was accompanied <br />during the inspection by Ms. Bailey Smith, Division Title V Permit Engineer. Ms. Kathy Welt, <br />Environmental Manager, escorted Division personnel during the inspection and, along with <br />several other MCC employees, provided facility operational information. Ms. Welt also provided <br />requested facility records and APEN submissions following the inspection. <br />Summary of operations: The facility consists of an underground coal mine (longwall mining), coal <br />storage, handling, crushing, screening, a coal wash plant, and a railcar loadout facility. The <br />facility is currently mining the E seam, which is connected to unsealed portions of the previously <br />mined B seam. The source is also actively rehabbing portions of the F seam. Coal from this <br />mine is considered high value as it is Low Sulfur, Low Ash, and high Btu (11,000-12,000 Btu/Ib). <br />Much of the facility's coal is sent east via railcar for blending with lower quality coal, thus creating <br />a more compliant fuel to be used in that region's electric utility plants. The mine opened in 1982, <br />and the current projected life of the mine at a 6.5-7 MMtpy extraction rate is through 2023. The <br />source reported that there have been the following modifications since the previous inspection in <br />2009: <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docz Page 1 of 30 <br />