2011-11-14_REVISION - C1981022 - Laserfiche WebLink

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Appeal Deciding Officer 27 once, in its analysis of emissions from mine operati on and coal transport, stating that “trace amounts of organic compounds [from diesel engines] ... can cause short -term odor problems. The 2000 Iron Point FEIS completely fails to address pollutants found in vented methane. Instead, the FEIS’s brief discu ssion of methane emissions states only that methane is vented to the atmosphere. The Forest Service cannot “tier” to or otherwise rely on an 11 -year -old analysis that omits any discussion of the most likely source of VOC pollution. Discussion: Also see t he discussion above in Appeal IV issue. Ozone is not emitted directly into the air but is formed by the reaction of Volatile Organic Compounds (VOCs ) and nitrogen oxide s (NOx ) in the presence of heat and sunlight. VOCs are emitted from a variety of source s, including motor vehicles, and other industrial sources. NOx is emitted from motor vehicles and other sources of combustion. The appellant argues that ozone analysis should have been completed directly for this lease modification based on the fact that the BLM conducted a rudimentary ozone analysis in the draft EIS for the nearby Red Cliff coal mine. However, it should be noted that the BLM analysis was for a n impact of a whole mine including surface disturbance. This lease modification clearly does no t authorize any new surface disturbance which would lead to an increase of VOC’s and NOx emissions which is discussed in the EA (Section 3.2 pages 41 to 60). The fact that this lease modification is significantly smaller in the amount of coal proposed for removal (35,0 00 to 235,000 tons equivale nt to addition of 2 days to 3 weeks of mining) and allows no new surface disturbance it was clearly sta ted in the EA that this will contribute such minor changes in the amounts of NOx or VOCs to the air , that th ose change s would not be readily evident in further modeling . The EA also states that “The equipment used for the lease modification will be the same equipment that is being used in the current mining operations. Therefore, the air quality impacts associated with the proposed mine expansion can be presumed to be equal to, or less than, impacts predicted in the original air quality impact assessment due to more stringent regulations.” The DN/FONSI was clear to state the Oxbow will be required to maintain the ir current APEN with the State of Colorado who has been delegated the authority over air quality regulation and enforcement. The proposed action is not anticipated to require any amendments or modification to the APEN. The issue of NOx and VOCs emission as well as their relationship to ozone is apparent in the analysis and was not overlooked. Recommendation: I recommend that the Forest Supervisor’s decision be affirmed on this point regarding analysis of ozone , NOx and VOCs .