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percentages (established as per the method described above), MCC's VOC emissions <br />could be as high as 394 to 406 tons per � Without a wider range of specific extended <br />gas analysis, the Division is unable to accurately estimate if the release of specific non - <br />criteria reportable pollutants has also exceeded the APEN-required thresholds listed in <br />AQCC Regulation 3, Part A, Section II.B.3.b. <br />Exhibit 1, APCD Inspection Report (Feb. 20, 2013, revised April 4, 2013) at 7-8 (emphasis in <br />original). Put another way, in 2012, the APCD determined that methane venting operations at <br />the West Elk mine, by virtue of the associated regulated VOC emissions, were violating state air <br />quality reporting requirements set forth under Air Quality Control Commission regulations as <br />well as permitting requirements set forth under these same regulations. Based on this finding, <br />the APCD found the West Elk mine to be "out of compliance" with state clean air laws and <br />regulations. <br />This finding was bolstered as the APCD gathered more data regarding the composition of <br />gas streams being vented by other coal mines in the vicinity of West Elk. In a 2014 memo that <br />was subsequently updated in 2015, the APCD confirmed both that VOC emissions related to coal <br />mine methane venting are an issue and that several coal mines in the state, including West Elk, <br />were in violation of reporting and permitting requirements. The APCD explained: <br />Even at extremely low concentrations of VOCs, because of the high volume of <br />gas/methane released, there can be substantial VOC emissions from underground coal <br />mines. Based on the newly acquired Oxbow exhaust gas testing results, and as originally <br />stated in my 2012 inspection reports, it is clear that there are uncontrolled VOC <br />emissions above reporting, construction permitting, and Title V permitting thresholds for <br />several of Colorado's gassy underground coal mines. <br />Exhibit 2, APCD, Coal mine VOC emissions — progress overview and summary of emissions <br />data (September 26, 2014, updated January 7, 2015). This memo confirmed that methane <br />venting at the West Elk mine was releasing regulated VOCs above legally required reporting and <br />permitting thresholds. In the chart below, the APCD illustrated how VOC emission rates from <br />West Elk, on a tons per year basis, exceeded several critical emission thresholds. <br />11 <br />