Laserfiche WebLink
Page 1 of 5 <br />s <br />(COLORADO <br />Department of Public <br />Health b Environment <br />Dedicated to protectmc, and improN ing the health and environnncnt of the people of Colorado <br />Memorandum - Confidential Deliberative <br />To: Paul Carr - Supervisor <br />Cc: Shannon McMillan - Unit Supervisor <br />From: Ben Cappa - Inspector <br />Date: 9/26/2014, Updated 1/7/2015 <br />Re: Coal mine VOC emissions - progress overview and summary of emissions data <br />Per requests to quantify potential emission rates associated with underground coal mines, the Division has obtained <br />associated emissions data while performing routine inspections. As a progress update for managers and to provide <br />direction on recommendations for next steps, the current data and significant events associated with this project are <br />summarized chronologically below. The project was initiated in March 2012 following a formal written complaint from <br />WEG/Sierra Club regarding unreported coal mine VOC emissions. Since that time, the Division has researched the <br />complaint and issued multiple information requests pursuant to the authority stated in C.R.S. 25-7-111. These requests <br />have since been placed in abeyance to support an informal cooperative information gathering process. To date, the <br />Division has not received any affirmative VOC emissions information from any of the underground coal mines originally <br />under review, so additional information has been acquired through routine inspections. <br />Chronology of events: <br />3/2/2012 - The Division received a written complaint from WEG/Sierra Club alleging that there are VOC emissions from <br />Colorado coal mines which have not been addressed in Construction or Title V Permits. The letter included calculations <br />for VOC and HAP emissions from Mountain Coal Company's (MCC) West Elk Mine, and also listed several other Colorado <br />coal mines as likely sources of VOC emissions exceeding Colorado's reporting thresholds, and possibly Title V permitting <br />thresholds. The letter also included the first testing data received by the Division regarding VOC emissions from the <br />West Elk Mine. The testing data was from two Methane Drainage Well (MDW) samples taken on 5/15/2009 (Sample well <br />#0851 and #0840). The tetter also included that methane emissions from several mines are likely above the EPA's <br />tailoring rule's threshold of 100,000 tpy COZeq, thus requiring the submission of a Title V Permit application by <br />7/1/2012. <br />6/14/2012 - Preliminary information regarding the complaint, including a draft request letter, draft list of mines, and <br />email correspondences regarding individual mines was provided to Division Inspector, Ben Cappa, with a directive to <br />begin investigating the emissions from coal mining, to prioritize mines to be included with the initial information <br />request, and to re -format the request as necessary. <br />June/July 2012 - Three coal mines (Bowie #2, MCC's West Elk Mine, and Oxbow) submit Title V Permit applications for <br />GHG's above the 100,000 tpy COZeq tailoring rule threshold. The applications reported criteria pollutant and COZeq <br />emissions, but did not include any VOC emissions data. <br />4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.coLorado.gov/cdphe r'� >r,�. <br />John W. Hickentooper, Governor I Larry Wolk, MD. MSPH, Executive Director and Chief Medical Officer A <br />Y <br />