2017-11-01_GENERAL DOCUMENTS - C1980007

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This is reinforced as the two extended gas analysis performed on both the high producing well and low producing well had similar NMEHC:CH4 ratio percentages. Therefore, using the total methane emissions data in the greenhouse gas reports, in conjunction with the 2009 extended gas analysis which were performed on two of the MDWs, the Division asserts that MCC has been operating with NMEHC/VOC emissions far above the APEN-required threshold of 2 tpy from individual points (Ref: AQCC Regulation 3, Part A, Section 11.6.3.a.), and the permit -required threshold of 5 tons per year from all APEN-required sources at the facility (Ref: AQCC Regulation 3, Part B, Section II.113.3.a.). As stated above, MCC reported with their recent greenhouse gas report that the facility emitted 51,290 tons of methane in 2011. Multiplying this value by the 0.768% and 0.791% NMEHC:CH4 ratio percentages (established as per the method described above), MCC's VOC emissions could be as high as 394 to 406 tons per year. Without a wider range of specific extended gas analysis, the Division is unable to accurately estimate if the release of specific non -criteria reportable pollutants has also exceeded the APEN-required thresholds listed in AQCC Regulation 3, Part A, Section 11.B.3.b. In order to obtain more accurate VOC emissions information, the Division has requested an extended gas analysis from several points at the mine (original request sent January 11, 2013 with a deadline for submission on March 11, 2013, a deadline which was later extended). This information will allow the source to more accurately estimate VOC emissions from all points, and will likely result in the submission of associated APENs for several points, possibly including the portable MDW pumps which remove gas from the gob directly above the active panel. POINT AIRS ID/PERMIT NUMBERS The following AIRS Points and equipment are located at this facility: AIRS Pt Permit No. Description 009 93GU886.XA One 15,000 gallon storage tank for diesel fuel and one 4,000 gallon storage tank for unleaded gasoline. Conveyors and Transfer Points: Main Mine Conveyor, Conveyor ST -1, 011 09GU1382 Conveyor 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, S/N: 154-81, breaker for crushing/sorting of coal. One (1) American Pulverizer, Model: Double 012 09GU1382 Roll, S/N: 7630, roll crusher. Two (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 09GU1382 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. 014 09GU1382 Particulate emissions are controlled by limiting storage area size, hauling limitations, and by following the approved fugitive dust control plan included in the permit. Coal refuse pile and associated mobile equipment and hauling of coal. 015 09GU1382 Particulate 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 016 09GU1382 previously hauled by truck for certain customers as well as to the wash lant located at the nearby Bowie facility. The source reported that this 2012 Air Pollution Inspection 0510015-INSP-2012.docx Page 8 of 30