2017-10-23_GENERAL DOCUMENTS - C1980007

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reach as high as —320 tpy. MCC has been aware that the Division was actively seeking information on this issue since September 2012, and has met with the Division along with other mine representatives to discuss the need for additional testing. MCC has not provided any testing or emissions estimates, and has not submitted an APEN to report VOC emissions or acquire appropriate permits since being made aware of this ongoing issue. During 2015 meetings, the Colorado Mining Association (representing individual mines regarding this project) intimated that they would work cooperatively with the Division to test, report, and ultimately permit their represented mines appropriately. Since that time, there has been no formal progress on this issue, meaning that there have been no testing results provided, no APENs submitted, and no permits modified. It is ultimately the individual mine's responsibility to accurately report emissions, in addition to submitting Construction Permit and Title V Operating Permit applications as needed. This issue was addressed in the 2012 inspection report stating that the Division and mines were initiating a process to obtain additional data and would address the issue appropriately from that point. Without any forthcoming data from the mines, the inspector has obtained additional testing data to support the original conclusion that MCC has VOC emissions above APEN and permit thresholds. As MCC has not acted since the 2012 inspection to test, report, or appropriately permit their facili , , the inspector now recommends enforcement action to address the ongoing violations that have not been resolved since the 2012 inspection. POINT AIRS ID/PERMIT NUMBERS The following AIRS Points and equipment are located at this facility: AIRS Permit No. Description Pt One 15,000 gallon storage tank for diesel fuel and one 4,000 gallon storage tank for 009 93GU886.XA unleaded gasoline. Conveyors and Transfer Points: Main Mine Conveyor, Conveyor ST -1, Conveyor 011 09GUI382 ST -2, and Conveyor ST -3. Particulate emissions are controlled by enclosures and natural moisture in coal. Coal Processing System, design rated at 1,650 tph, and consisting of. One (1) McLanahan, Model: Rotary Breaker, SN: 154-81, breaker for crushing/sorting of coal. One (1) American Pulverizer, Model: Double Roll, SN: 7630, roll crusher. Two 012 09GU1382 (2) Tabor, Model: Coal Screen, S/Ns: 4511 and 4512, vibrating screens. One (1) Custom reject bin. Seven (7) Custom, conveyors for coal and reject material. Particulate emissions are controlled by enclosures and natural moisture in coal. Two (2) storage silos for coal storage (7,700 ton and 16,000 ton capacity 013 09GU 13 82 respectively). Two (2) vibratory feeders. One (1) train loadout conveyor. One (1) batch weigh system. One (1) coal sampling system. Particulate emissions are controlled by enclosures and natural moisture in coal. Storage pile, emergency stockpile, and associated hauling of coal. Particulate 014 09GU 1382 emissions are controlled by limiting storage area size, hauling limitations, and by following the approved f i itive dust control plan included in the permit. Coal refuse pile and associated mobile equipment and hauling of coal. Particulate 015 09GU1382 emissions are controlled by following the approved fugitive dust control plan included in the permit. Hauling of coal from the Run Of Mine (ROM) storage pile. Coal was previously hauled by truck for certain customers as well as to the wash plant located at the nearby 016 09GU1382 Bowie facility. The source reported that this point/activity is not currently in operation, but it is possible that they may utilize this activity again in the future. 019 109GUI382 I Coal Mine Ventilation Shafts: 2015 Inspection �� 0510015-INSP-2015 Page 5 of 37