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enforcement action which may require a review of site-specific extended gas
<br />analysis from multiple points, the source may be found to be subject to OP
<br />requirements for VOCs, in addition to being a Title V source for greenhouse gases.
<br />Compliance with this condition cannot be assessed at this time.
<br />INSPECTION SUMMARY/CONCLUSION
<br />This compliance assessment is based on observations made during the inspectioti,
<br />information provided by the source, and a review of Division records. Based on this,
<br />Mountain Coal Co, LLC — West Elk Mine ('MCC') is determined to NOT be in compliance
<br />with the Conditions of Permit No. 09GU1382.IA and applicable Colorado Air Quality,
<br />Control Commission Regulations. Specifically, the source is in violation of the following:
<br />A. Pursuant to AQCC Regulation 3, Part A, §II.A and Permit 09GUl382 Condition 8.b
<br />and 8.d, no person shall allow emission of air pollutants from, or construction;
<br />modification, or alteration of, any facility, process, or activity which constitutes a
<br />stationary source, from which air pollutants are, or are to be, emitted unless afid
<br />until an Air Pollutant Emission Notice ("APEN") and the associated APEN fee has
<br />been filed with the Division with respect to such emission. MCC has been operating
<br />a pneumatically loaded rock dust silo equipped with a pulse jet baghouse to control
<br />particulate matter emissions for many years. MCC did not submit an APEN for the
<br />silo until February 15, 2012, violating AQCC Regulation 3, Part A, §II.A. and Permit
<br />09GU1382 Condition 8.b & 8.d.
<br />B. Pursuant to AQCC Regulation 3, Part B, §II.A.1, no person shall commence
<br />construction of any stationary source without first obtaining or having a valid
<br />construction permit from the Division. MCC has been operating a pneumatically
<br />loaded rock dust silo equipped with a pulse jet baghouse to control particulate
<br />matter emissions for many years. MCC has not yet obtained a valid permit for the
<br />rock dust silo activities. MCC failed to obtain a permit for the rock dust silo
<br />activities, violating AQCC Regulation 3, Part B, §11.A.1.
<br />C. Pursuant to AQCC Regulation 3, Part A, §II.A and Permit 09GU1382 Condition. 8.b.
<br />and 8.d, no person shall allow emission of air pollutants from, or construction,
<br />modification, or alteration of, any facility, process, or activity which constitutes a
<br />stationary source, from which air pollutants are, or are to be, emitted unless and
<br />until an Air Pollutant Emission Notice ("APEN") and the associated APEN fee has
<br />been filed with the Division with respect to such emission. MCC installed and has
<br />been operating an NSPS Subpart IIII applicable, emergency diesel backup ,generator
<br />for the main office building server since 2010. MCC did not submit an APEN for the
<br />associated engine until February 15, 2012, violating AQCC Regulation 3, Pgrt A; §II.A.
<br />and Permit 09GU1382 Condition 8.b & 8.d.
<br />D. Pursuant to AQCC Regulation 3, Part B, §II.A.1, no person shall commence -
<br />construction of any stationary source without first obtaining or having a valid
<br />construction permit from the Division. MCC installed and has been operating an
<br />NSPS Subpart IIII applicable, emergency diesel backed generator for the main office
<br />building server since 2010. MCC has not yet obtained a valid permit for the
<br />associated engine. MCC failed to obtain a permit for the engine, violating AQCC
<br />Regulation 3, Part B, §11.A.1.
<br />2012 Air Pollution Inspection
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