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operating permit. The Division has obtained sufficient information to determine MCC has been <br />operating with VOC emissions from ventilation shafts above the 100 tpy major source threshold <br />since at least 2011 (the start date of when methane data was available). MCC has been aware of the <br />Division's review of this information, and has not provided credible information to repudiate this <br />determination. MCC has not submitted a Title V application which included reporting VOC <br />emissions or requested an operating permit for these emissions, violating Permit 09GUI382 <br />Condition 14 and AQCC Regulation 3, Part C. <br />Note: Violation C is reliant on the inspector's determination that emissions exiting the mine's <br />ventilation shafts are considered "point" rather than "fugitive" emissions. Fugitive emissions are <br />defined in AQCC Common Provisions Regulation Section I.G. to be "Emissions that could not <br />reasonably pass through a stack, chimney vent or other functionally equivalent opening." The <br />mine's VOC emissions are being released in small quantities from stacks of portable Mine <br />Ventilation Borehole systems, and primarily from the mine's ventilation stacks. These emissions are <br />being routed through an air handling system and out an enclosed stack, and do not meet the <br />definition of fugitive emissions. Similarly, to support this point -source determination, the fugitive <br />emissions definition is not affected by the emissions being found naturally underground (prior to <br />being released by mining activities), being required to be released to provide safe ventilation air for <br />workers, or that the emissions are released in low concentrations from a high volume stack. <br />Previously, the Division has applied a similar determination to the particulate emissions released <br />from the ventilation stacks. <br />The violations listed under B. and C. above have remained ongoing for several years. The source <br />and Division do not currently have a timeline in effect or clear outline of how these violations will <br />be resolved. The source has been aware of these violations for several years without taking <br />appropriate mitigating steps. For this reason, enforcement action is recommended to address the <br />violations listed above, excluding APEN violations listed in Violation A. above. <br />July Report Revision: The Division has determined that an enforcement case will not be initiated to <br />address the violations listed above. <br />COMPLIANCE STATUS: <br />2015 Inspection <br />0510015-INSP-2015 <br />IN COMPLIANCE [ ] OUT OF COMPLIANCE [ X ] <br />AIT <br />Page 36 of 37 <br />