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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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Page 3 of 5 <br />July 2013 - The Division was directed to form 'work groups' with the mines and CMA to work through request letter <br />issues (i.e. testing low concentrations in large diameter high volume exhaust stacks, seasonal/geologic variability in <br />VOC concentrations, and applicable testing protocols). However, the Division believes the issues raised by CMA have <br />been resolved, are unrelated to the scope of the request, or have been proven to be factually incorrect. <br />7/19/2013 - BLM contacted the Division requesting information on VOC emissions from coal mines, needed for their <br />modeling and permitting decisions. As they were aware of the previous Division information requests, when informed <br />that no data had yet been obtained, the BLM responded that it is "unfortunate" that the Division was no longer really <br />pursuing the request, as other agencies rely on our information and knowledge on these topics. <br />8/15/2013 - CMA submits 'Proposed VOC Working Group' document with issues to discuss and a proposed schedule. <br />Issues to discuss include the appropriateness of regulating VOC emissions, the potential misinterpretation of VOC data <br />by third parties, and protection from Division enforcement actions regarding VOCs. <br />11/19/2013 - CMA, Coal Mine representatives, and Division management met. <br />1/27/2014 - CMA presented information to the Division regarding the complex ventilation systems utilized underground <br />for worker safety, but did not provide insight into why sampling exhaust ports may be unreasonable/impossible. <br />Jan 2014 to Present - No upper management direction has been provided for staff to resume pursuing Division <br />information requests, meetings with CMA, or to work through outstanding 'issues' regarding sampling/ reporting of VOC <br />emissions from mines. <br />3/25/2014 - CMA, through counsel, submitted a response to the information request in January and April 2013, and <br />presented their position regarding whether these emissions should be considered fugitive or point source. Note: <br />emissions from both point and fugitive sources are required by regulation to be reported. To date, the information <br />requested has not been provided. <br />July 2014 - Following the Supreme Court ruling that sources would not be required to obtain a Title V permit if they <br />are subject solely due to GHG emissions, Bowie #2, Oxbow, and MCC withdrew their Title V applications which were <br />submitted in June/July 2012. <br />7/16/2014 - A routine full compliance inspection of Vessels Coal Gas, Inc (Vessels) was preformed. Vessel's operates <br />electric generating engines and a flare, run exclusively on the exhaust gas from the Oxbow coal mine. As part of the <br />inspection, the Division requested fuel gas analysis data for tests which were reported to have been previously <br />conducted. This was requested to ensure compliance with existing permit terms, and to also estimate uncontrolled <br />actual emissions, since approximately 80% of Vessels' intake gas is flared. <br />8/4/2014 - Vessels provided results for fuel gas sampling performed on 2/20/2014 from Oxbow's mine exhaust. These <br />gas analyses, in addition to the 2009 MCC coal mine methane drainage well emission test results, were used in <br />combination with the 2012 EPA Reported Methane emissions from seven (7) Colorado underground coal mines (not <br />including GCC) to determine estimated VOC emissions. <br />8/13/2014 - Vessels provided a second set of intake gas sampling results for tests performed on 8/11/2014. These <br />results were used in addition to the previous Vessels' 2/20/2014 results, two MCC testing results from 2009, and 2012 <br />EPA reported methane emissions, in order to estimate a range of possible VOC emissions from seven (7) underground <br />coal mines in Colorado. The calculated results are summarized in the following table: <br />Expectedly, methane concentrations and ambient air concentrations in samples were not identical. Therefore, based <br />on individual sample speciation results, each sample (or set of samples for Oxbow tests) was assigned a VOC:Methane <br />4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe ,fig c_a©� <br />John W. Hickentooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer�4 <br />\ x j876., i <br />
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