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Page 3 of 5 <br />July 2013 - The Division was directed to form 'work groups' with the mines and CMA to work through request letter <br />issues (i.e. testing low concentrations in large diameter high volume exhaust stacks, seasonal/ geologic variability in <br />VOC concentrations, and applicable testing protocols). However, the Division believes the issues raised by CMA have <br />been resolved, are unrelated to the scope of the request, or have been proven to be factually incorrect. <br />7/19/2013 - BLM contacted the Division requesting information on VOC emissions from coal mines, needed for their <br />modeling and permitting decisions. As they were aware of the previous Division information requests, when informed <br />that no data had yet been obtained, the BLM responded that it is "unfortunate" that the Division was no longer really <br />pursuing the request, as other agencies rely on our information and knowledge on these topics. <br />8/15/2013 - CMA submits 'Proposed VOC Working Group' document with issues to discuss and a proposed schedule. <br />Issues to discuss include the appropriateness of reguiating VOC emissions, the potential misinterpretation of VOC data <br />by third parties, and protection from Division enforcement actions regarding VOCs. <br />11/19/2013 - CMA, Coal Mine representatives, and Division management met. <br />1/27/2014 - CMA presented information to the Division regarding the complex ventilation systems utilized underground <br />for worker safety, but did not provide insight into why sampling exhaust ports may be unreasonable/impossible. <br />Jan 2014 to Present - No upper management direction has been provided for staff to resume pursuing Division <br />information requests, meetings with CMA, or to work through outstanding 'issues' regarding sampling/ reporting of VOC <br />emissions from mines. <br />3/25/2014 - CMA, through counsel, submitted a response to the information request in January and April 2013, and <br />presented their position regarding whether these emissions should be considered fugitive or point source. Note: <br />emissions from both point and fugitive sources are required by regulation to be reported. To date, the information <br />requested has not been provided. <br />July 2014 - Following the Supreme Court ruling that sources would not be required to obtain a Title V permit if they <br />are subject solely due to GHG emissions, Bowie #2, Oxbow, and MCC withdrew their Title V applications which were <br />submitted in June/July 2012. <br />7/16/2014 - A routine full compliance inspection of Vessels Coal Gas, Inc (Vessels) was preformed. Vessel's operates <br />electric generating engines and a flare, run exclusively on the exhaust gas from the Oxbow coal mine. As part of the <br />inspection, the Division requested fuel gas analysis data for tests which were reported to have been previously <br />conducted. This was requested to ensure compliance with existing permit terms, and to also estimate uncontrolled <br />actual emissions, since approximately 80% of Vessels' intake gas is flared. <br />8/4/2014 - Vessels provided results for fuel gas sampling performed on 2/20/2014 from Oxbow's mine exhaust. These <br />gas analyses, in addition to the 2009 MCC coal mine methane drainage well emission test results, were used in <br />combination with the 2012 EPA Reported Methane emissions from seven (7) Colorado underground coal mines (not <br />including GCC) to determine estimated VOC emissions. <br />8/13/2014 - Vessels provided a second set of intake gas sampling results for tests performed on 8/11/2014. These <br />results were used in addition to the previous Vessels' 2/20/2014 results, two MCC testing results from 2009, and 2012 <br />EPA reported methane emissions, in order to estimate a range of possible VOC emissions from seven (7) underground <br />coal mines in Colorado. The calculated results are summarized in the following table: <br />Expectedly, methane concentrations and ambient air concentrations in samples were not identical. Therefore, based <br />on individual sample speciation results, each sample (or set of samples for Oxbow tests) was assigned a VOC:Methane <br />4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe <br />John W. Hickenlooper. Governor I Larry Wotk, MD. MSPH, Executive Director and Chief Medical Officer ` <br />+ rt <br />