GENERAL39717

• Permit No: C1996084
• IBM Index Class Name: General Documents
• Doc Date: 2/7/2002
• Doc Name: RESPONSE TO REQUEST FOR ASSISTANCE LORENCITO CANYON MINE C-96-084
• From: DEPT OF PUBLIC HEALTH & ENVIRONMENT
• To: DMG
• Permit Index Doc Type: CITIZEN COMPLAINTS
• Media Type: D
• Archive: No

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999
STATE OF COLORADO
Uill Owens, Governor
lane E. Norton, Executive Director ~~, of.eo~
Dedicated to protecting and improving the health and environment of the people o1 Colorado ~° ~ pO~-{} p~O
4300 Cherry Creek Dr. 5. Laboratory and Radiation Services Division "~ "`- +t
Denver, Colorado 00246-1530 8100 Lowry Blvd. • te~i6 ~
Phone [phone] Denver, Colorado 80 2 3 0-69 2 71
TDD Line (3031 691-7700 (3031 692-3090 Colorado Departure
Located in Glendale, Colorado
of public Health
htrp://www.cdphesrate.co.us and Environt»en[
~iECE!`JED
Mr. Kent Gorham FEB 0 7 2002
Division of Minerals & Geology February 4, 2002
Department of Natural Resources Division of Minerals and Geology
1313 Sherman St. Rm. 215
Denver, CO 80203
Re: Response to "Request for Assistance, Lorencito Canyon Mine, #C-96-084"
Mr. Gorham:
Regarding your letter dated January 29, 2002 in the matter of complaints related to fugitive coal
dust emissions deposited to the east of Lorencito Coal Company's (Lorencito) coal load-out area. The Air
Pollution Control Division (Division) received a telephone complaint from Mr. Ron Leef on December
11, 2001, claiming that a layer of coal dust approximately 0.25 inch thick was on the river banks and
frozen surface of a stream east of the Lorencito coal load-out azea. The Field Enforcement Officer (FEO)
Mr. Paul Carr contact Lorenci[o's Superintendent, Mr. Elmer Bentley, on December 11, 2001 to inform
Lorencito of the complaint and the Division's enforcement responsibility specifically related to the
emission of fugitive dust. On December 15, 2001, the FEO conducted an unannounced inspection of the
Lorencito facility to observe blasting activities and to inspect the vicinity near the coal load-out operations
for evidence of fugitive dust emissions. A front-end loader was moving coal into piles in the load-out area
but no rail car loading was observed during the inspection. The FEO inspected a radius of approximately
1000 feet east of the coal load-out area. The only evidence of coal dust observed was a slight dusting of
fine coal deposited on blades of short grass and weeds approximately 100 feet east-by-northeast of the
load-out azea. Colorado Air Quality Control Regulation 1, section III., D. ,2. ,d. requires mining activities
to comply with both the 20% opacity and no off-property transport of fugitive dust standards (specific
citation enclosed, entire regulation available on-line at t~:/iwww.cd~he.state.co.usiop/aitre~s.asp). No evidence
of coal dust was observed in the stream, on the banks, or off Lorencito's property during the inspection so
the Division initiated no enforcement actions. The FEO informed Lorencito's Dav Forman, Mr. Daniel
Risner, of Lorencito's permitted responsibility to control dust emissions from all mining activities, as well
as, the Division's concerns about mining activities conducted when there is the high potential for off-
property transport of fugitive emissions based on wind speed and direction.
Additional inspections were conducted at the Lorencito facility on January 7, 2002 and January 9,
2002, to observe blasting activities and to evaluate the Division's concerns about Lorencito's ability to
control fugitive emissions. In an attempt to better control unpredictable emissions and protect public and
environmental health, the Division sent a letter to Lorencito (dated February 1, 2002, enclosed) proposing
to revise the permit language in O1LA0642 to include additional fugitive control measures, in addition to