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2017-10-23_GENERAL DOCUMENTS - C1980007
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2017-10-23_GENERAL DOCUMENTS - C1980007
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Last modified
10/24/2017 7:12:12 AM
Creation date
10/24/2017 6:56:38 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
General Documents
Doc Date
10/23/2017
Doc Name
Compliant and Request for Inspection Over Failure of West Elk
From
Wild Earth Gurdians
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
LDS
Media Type
D
Archive
No
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measures the total amount of gas consumed in all combined burners for all shafts, but does not <br />record the amount burned for each point. MCC reported in their 2011 Greenhouse Gas report <br />submitted to EPA that they burned a total of 6,882,298 scf of methane (the only tested gas in the <br />samples) in these burners. According to the May 2012 Draft Environmental Impact Statement <br />concerning the new Federal Coal Lease Modifications COC -1362 & COC -67232 for activities at <br />the West Elk Mine, although this gas had not been measured, the EPA estimated that the site <br />burned 170 mmscf of methane in their burners in 2006. Applying the AP -42 Table 1.4-1 NOx and <br />CO emission factors for natural gas burners (100 lbs/mmscf and 84 lbs/mmscf respectively), the <br />EPA listed gas use of 170 mmscf would require an APEN submission, as NOx and CO emissions <br />would equal approximately 8.5 and 7.1 tons per year respectively. As the estimation <br />methodology used by the EPA is not explained in the corresponding EPA report, this unmeasured <br />gas usage does not allow the inspector to confirm the accuracy of their estimation based on the <br />information provided. Alternately, MCC's reported gas usage of 6,882,298 scf of methane in <br />2011 allows the inspector to estimate that the combustion emissions from this activity are below <br />APEN reporting thresholds (less than 0.5 tons NOx and CO). No additional APEN submissions <br />are required for this activity at this time. <br />-Rock Dust Silo: It was observed during the inspection that the West Elk mine utilizes an <br />aboveground storage silo for rock dust. This silo is filled pneumatically by truck, and emissions of <br />the finely ground limestone are controlled by a pulse jet baghouse (See Picture #3). At the time <br />of the inspection, the silo was being loaded, and the baghouse appeared to be unable to control <br />emissions as designed. Emissions from the baghouse varied between 15-25% opacity, with <br />higher bursts of opacity during pulse jet cleaning. It was noted that the silo was being loaded at <br />15 psi, and the driver believed that there was no psi restriction on loading. The visible emissions <br />observed were either a result of a lack of maintenance being performed on the baghouse, or the <br />unit was being loaded at too high of a pressure. In either case, MCC was asked to address the <br />issue. MCC reported that the emissions observed during the inspection were the result of an <br />incorrectly installed access door gasket, which was replaced immediately following the inspection. <br />They reported that there have been no visible emissions observed from the point since the <br />replacement. Furthermore, in a letter response received by the Division on January 11, 2013, the <br />source indicated that they perform weekly inspections of the baghouse, and emissions have not <br />been observed coming from the baghouse vents. Based on the amount of rock dust located <br />around the base of the silo and spread along the wall next to the baghouse, it seems likely that <br />emissions from this point persisted without response for an extended period of time (See Picture <br />#4). <br />The source was also asked to address the issue relating to the recommended loading pressure of <br />the rock dust silo, as the unit was being loaded at 15 psi during the inspection with visible <br />emissions. Based on the information provided, it appears that the emissions were due to a <br />damaged door gasket. However, in the 1/11/2013 response, the source stated that "In summary, <br />the opacity observed from the faulty door gasket was not at all caused by the trucks `loading at <br />too high a pressure', as the system is open to the atmosphere and is not impacted by pressure <br />from the trucks." This statement is incorrect in that the loading pressure is a direct measure of <br />the amount of force being exerted through the delivery system, including in the baghouse/bags, <br />and a level of loading pressure above the recommended standard can result in damage to the <br />filter system and/or the silo. The source was requested to re-evaluate the loading procedure for <br />the unit and ensure that appropriate psi is utilized during loading. <br />Furthermore, as underground coal mines of this size typically use thousands of tons per year of <br />rock dust, MCC should have submitted an APEN requesting Division review of this point. It was <br />noted in the Division's Permit Tracking System (PTS) that MCC discussed the issue of the rock <br />dust silo requiring an APEN during a conversation on 11/30/2010 (see Picture #5). The source <br />contended in the response received 1/11/2013 that the baghouse system on the rock dust silo is <br />intended to capture product during loading, and should not be considered a control device. <br />According to Mr. Chip Hancock, Construction Permit Engineer Supervisor, this interpretation is <br />not consistent with the Division's policy for these units. As was observed during the inspection, <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 5 of 30 <br />
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