2017-11-01_GENERAL DOCUMENTS - C1980007

• Permit No: C1980007
• IBM Index Class Name: General Documents
• Doc Date: 11/1/2017
• Doc Name: Request for Informal Review
• From: Wild Earth Guardians
• To: DRMS
• Permit Index Doc Type: General Correspondence
• Email Name: JRS
• Email Name: LDS
• Media Type: D
• Archive: No

Page 4 of 5
ratio percentage by dividing the total percent of VOC by the total percent of methane in each sample. This ratio was
then multiplied by 2012 EPA -reported yearly methane emissions from each mine to establish total VOC emissions based
on each samples' analysis. This methodology yielded similar total VOC results for the MCC samples taken on the same
day (even though they had very different methane concentrations), and similar results for the Oxbow samples (taken
on two days separated by six (6) months).
Estimated VOC emissions using 2012 CH4 data (in US short tons):
Shaded boxes indicate values from samples taken at respective mines
*Parenthetical values in top row represent VOC:Methane ratios calculated for each sample
**These three mines are in close geographic proximity and are considered 'gassy' mines (see map on next page)
Below is a graphical illustration of the information included in the previous table, including reference to applicable
thresholds:
ons VOC
2012 Total
CH4 reported
to EPA
VOC by MCC
#0851 Sample
(0.007677)*
VOC by MCC
#0840 Sample
(0.007913)*
VOC by
2/20/14 Oxbow
Sample
(0.005216)*
VOC by
8/11/14 Oxbow
Sample
(0.006048)*
Oxbow --Elk Creek**
51 574.5
395.9
408.1
269.0
311.9
MCC - West Elk**
40 672.4
312.2
321.8
212.1
246.0
Bowie No. 2**
14,623.5
112.3
115.7
76.3
88.4
McClane Canyon
1,080.9
8.3
8.6
5.6
6.5
Twent mile
755.7
5.8
6.0
3.9
4.6
Blue Mt Energy
341.1
2.6
2.7
1.8
2.1
Sage Creek
0
0
0
0
0
Shaded boxes indicate values from samples taken at respective mines
*Parenthetical values in top row represent VOC:Methane ratios calculated for each sample
**These three mines are in close geographic proximity and are considered 'gassy' mines (see map on next page)
Below is a graphical illustration of the information included in the previous table, including reference to applicable
thresholds:
ons VOC
Tons VOC
450
l0
• MCC #0851 Sample
• MCC #0851 Sample
400
• MCC #0840 Sample
9
• MCC #0840 Sample
Oxbow 2/20/14 Sample
8
350
Oxbow 2J20/14 Sample
• Oxbow 8/11/14 Sample
7
•Oxbow 8/11/14 Sample
300
6
Permit
250
PSD threshold
5
threshold
k"
4
200
3
150
2
APEN
threshold
1003
Title V
1
threshold
0
50
a
0
Permit
threshold
9¢u�1a
Oxbow -Elk MCC - West Bowie No. 2
Creek Elk'
�`Je
Conclusion:
Even at extremely low concentrations of VOCs, because of the high volume of gas/ methane released, there can be
substantial VOC emissions from underground coal mines. Based on the newly acquired Oxbow exhaust gas testing
results, and as originally stated in my 2012 inspection reports, it is clear that there are uncontrolled VOC emissions
above reporting, construction permitting, and Title V permitting thresholds for several of Colorado's gassy underground
coal mines.
4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe \ s
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer