HomeMy WebLinkAboutDAQ-2024-0109671
DAQC-CI100920001-24
Site ID 10092 (B1)
MEMORANDUM
TO: FILE – CANYON FUEL COMPANY, LLC – Skyline Mines
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Daniel Riddle, Environmental Scientist
DATE: October 8, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Carbon County
INSPECTION DATE: July 10, 2024
SOURCE LOCATION: Eccles Canyon
Scofield, UT 84526
DIRECTIONS: Take US-6 east toward Price. Turn right onto UT-96 south to
Scofield in Spanish Fork Canyon. Continue on UT-96 south past
Scofield and stay on UT-96 south as it becomes UT-264 west by the
lower mine rail load out. Follow UT-264 west for 2.7 miles. The
main office is located where the overland conveyor begins.
SOURCE CONTACTS: Brayden Wilson, Environmental Engineer
435-448-2685, bwilson@wolverinefuels.com
OPERATING STATUS: Operating normally at time of inspection.
PROCESS DESCRIPTION: Coal is mined from an underground mine using hydraulic cutters and
loaders. Water sprays are used during the mining process to reduce
dust (explosion hazard). The coal is conveyed out of the mine to the
surface by a specialty conveyer belt and conveyed to a transfer
building and then storage silo (with baghouse) or stacker tube and
pile. If the coal is transferred to the stacker tube and pile, it is
reintroduced to the transfer belt and silo by an under-pile feeder and
belt through the transfer building. Coal from the silo or transfer belt
goes to the crusher/screening building, which is fully enclosed and
controlled by an upper and lower baghouse. The material is crushed
to -2 inches. The lower baghouse also controls the feed end of the
conveyor system. Coal from the crusher is transferred to either a
truck load-out facility or to a 2.2-mile enclosed conveyor system.
The conveyor has a zippered belt, which forms a tube system for the
entire length of the trip. The conveyor feeds two 15,000-ton storage
silos (both equipped with baghouses) or an overage storage pile. Coal
from the stockpile is loaded into haul trucks and trains or transferred
to the storage silos. The silos have conveyors that feed coal to either
a rail load-out or a stoker coal truck load-out. Both are controlled by
baghouses.
2
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN100920003-21, dated
September 29, 2021
NSPS (Part 60) Y: Standards of Performance for Coal
Preparation and Processing Plants,
MACT (Part 63) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Canyon Fuel Company, LLC
Skyline Mines
A Subsidiary of Wolverine Fuels, LLC
597 South SR 24
Eccles Canyon
Salina, UT 84654 Scofield, UT 84526
SIC Code: 1222: (Bituminous Coal Underground Mining)
Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
3
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. An emissions
inventory was submitted for 2023, and emissions data are reported below.
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: Out of Compliance. The source did not submit documentation within the 18-month
window. Compliance assistance was provided. The source stated on September 10, 2024,
that they would write a memo to the director to notify the DAQ on the status of this AO.
No further action is recommended at this time.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment: II.A.1 Skyline Mines II.A.2 Main Conveyor (8,000,000 tons per year throughput) Drive - Long Airdox, 84 inches wide, 2,000 HP Rollers - Continental Conveyor, 84 inches wide Belt - George Duck Belt II.A.3 Two (2) Crushers Capacity: 1,500 TPH each II.A.4 Two Screens (70 tph throughput each) Thunderbird, 5162.4-14 Inclined Screen Allis Minerals, Low-Head Horizontal Screen II.A.5 Stoker Bin Capacity: 1,900 tons Bin located at lower mine site II.A.6 Rock Bin Capacity: 400 tons Bin located at lower mine site II.A.7 Three (3) Coal Silos Capacities: 8,000 tons, 15,000 tons, and 15,000 tons II.A.8 Two (2) Emergency Engines Rating: 2,000 HP each Fuel: Ultra-low sulfur diesel (ULSD) Manufacture Year: 2002 II.A.9 Tube Stacker Chute
4
II.A.10 Conveyors Various Transport Conveyors including a new conveyor extension for the new Tube Stacker Chute II.A.11 Three (3) Load-out Stations Tipple Truck Load-out, upper mine site Stoker Truck Load-out, lower mine site Rail Load-out, lower mine site II.A.12 Three (3) Fabric Filter baghouses Day Model 72RF10 for ROM silo area Day Model 72RF10 for ROM silo area Day Model 72RF10 for crusher area II.A.13 Two (2) Fabric Filter Baghouses Dynaclone Model 6A for storage silos II.A.14 One (1) Fabric Filter Baghouse Dynaclone Model 7A for rail load-out II.A.15 Fifteen (15) Space Heaters Natural gas-fired heaters at various locations II.A.16 Two (2) Boilers Natural gas-fired boilers manufactured by Kewanee Boiler Corp. and model number L3W-125-G. They are each rated at 5 MMBtu for main shop building heat.
Status: In Compliance. No unapproved equipment was observed at the source. The two new
generators in II.A.8 have been installed at Swen's Canyon – a portion of the mine
property located about 2 miles further west on Highway 264. One of the crushers
(II.A.3) has been removed from service. In II.A.7, the 8,000 tons coal silo is the ROM
silo, and the two 15,000 tons silos are located at the lower mine site.
II.B Requirements and Limitations
II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not exceed the following direct offsite shipment limits:
A. 8,000,000 tons per rolling 12-month period of coal and waste material combined
B 4,500,000 tons per rolling 12-month period of coal from each individual load-out.
[R307-401-8]
II.B.1.a.1 The owner/operator shall:
A. Determine direct offsite shipments by supervisor monitoring and maintenance of an
operations log.
B. Record shipments on a monthly basis
C. Use the shipment data to calculate a new rolling 12-month total by the 20th day of each
month using data from the previous 12 months
D. Keep the shipment records for all periods the plant is in operation.
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[R307-401-8]
Status: In Compliance. For the rolling 12-month period from June 2023 – May 2024:
A. 3,298,487 tons of coal and waste material combined
B. 2,896,055 tons from all load-outs combined
See the attached spreadsheets and email correspondence.
II.B.1.b The owner/operator shall not exceed the following production limits:
A. 600,000 tons maximum size in the upper elevation stockpile
B. 8,000,000 tons maximum size from the upper elevation stockpile and lower elevation
stockpile combined
C. 300 tons maximum size in the emergency storage pile
D. 500,000 tons maximum size in the lower elevation stockpile.
[R307-401-8]
II.B.1.b.1 The owner/operator shall:
A. Determine production with examination of company coal sales records and examination
of company throughput records for the points in question
B. Record production on a monthly basis
C. Use the production data to calculate a new rolling 12-month total by the 20th day of each
month using data from the previous 12 months
D. Keep the production records for all periods the plant is in operation.
[R307-401-8]
Status: In Compliance. For the rolling 12-month period from June 2023 – May 2024:
A. 357,682.57 tons was the largest monthly inventory reported in the upper elevation
stockpile.
B. 373,682.57 tons was the largest monthly inventory reported for the lower and
higher elevation stockpiles combined.
C. 0 tons. The emergency storage pile is not currently in use.
D. 16,000.00 tons was the largest monthly inventory reported for the lower elevation
stockpile.
See the attached stockpile inventory totals.
6
II.B.1.c The owner/operator shall transfer coal only by enclosed conveyor. Inter-site truck haulage
between the upper mine site and lower mine site may be used only during conveyor emergency
periods. [R307-401-8]
Status: In Compliance. All coal is transferred in the enclosed, overland conveyor. The
source was familiar with the requirements of this condition and confirmed they are
operating accordingly.
II.B.1.d The owner/operator shall utilize flaps on the entry and discharge ends of each conveyor transfer
point. [R307-401-8]
Status: In Compliance. All conveyor transfer points were observed to be enclosed and
contain flaps on entry and discharge ends.
II.B.1.e The owner/operator shall route all emissions from the ROM Silos to two fabric filter baghouses,
Day Model 72RF10, as necessary to prevent visible emissions from exceeding 20% opacity.
[R307-401-8]
Status: In Compliance. The baghouses were observed at the time of inspection. The source
operates a real-time coal scanning system. Whenever moisture drops below 4%, the
baghouses turn on automatically. Coal samples are sent daily to SGS Laboratories in
Huntington, UT to provide quality control validation for the real-time coal scanning
system. No opacity was observed from the ROM baghouses during the inspection.
II.B.1.f The owner/operator shall route all emissions from crushing and screening operations to a fabric
filter baghouse, Day Model 72RF10, as necessary to prevent visible emissions from exceeding
7% opacity. The owner/operator shall enclose all crushing and screening operations.
[R307-401-8]
Status: In Compliance. All crushing and screening operations were observed to be
enclosed, vented, and controlled by a baghouse. The coal scanning system also monitors
the crushing and screening operations and activates the baghouse accordingly. No opacity
was observed from the crushing and screening operations during the inspection.
II.B.1.g The owner/operator shall route all emission from Silo No. 1 and Silo No. 2 to the two fabric filter
baghouses, Dynaclone Model 6A or equivalent, as necessary to prevent visible emission from
exceeding 20% opacity. [R307-401-8]
Status: In Compliance. The two lower elevation silos were observed with a previous
inspection to be rated at 15,000 tons each and controlled by two baghouses. The baghouses
are activated when excessive dust is detected by the scanning system. No opacity was
observed from Silo No. 1 and Silo No. 2 at the lower mine site during the inspection.
II.B.1.h The owner/operator shall route all emissions from The Headhouse (rail load out) to a baghouse,
Dynaclone Model 7A or equivalent, as necessary to prevent visible emissions from exceeding
20% opacity. The owner/operator shall enclose all storage piles at train loadout facilities.
[R307-401-8]
Status: In Compliance. The Headhouse baghouse is monitored and controlled by
pressurized fabric filters when warranted by excessively dry coal. No opacity was observed
coming from the Headhouse baghouse during the inspection.
7
II.B.1.i The owner/operator shall utilize water sprays or chemical dust suppression sprays at the
following points (unless a baghouse controlling enclosed equipment is installed) to control
fugitive emissions:
A. All crushers
B. All screens
C. All conveyor transfer points.
[R307-401-8]
II.B.1.i.1 The sprays shall operate to maintain the opacity limits in this AO. [R307-401-8]
Status: In Compliance. All emission points referenced in this condition are enclosed and
controlled by baghouses when the scanning system detects that the product is dry.
Additionally, the source stated that they do have water sprays to maintain the opacity
limits as needed.
II.B.1.j The moisture content of the material shall be maintained at a value of no less than 4% of water
by weight. The moisture content shall be tested, if directed by the Director, using the appropriate
ASTM method. [R307-401-8]
Status: In Compliance. The source indicated the coal is watered as it is mined and the
material is tested for moisture content. Moisture content in the past 12 months ranged
from 5.15% to 7.42%. See attached coal moisture spreadsheet.
II.B.1.k The owner/operator shall water the storage piles as necessary to prevent visible emissions from
exceed 20% opacity during recovery operations only or as determined necessary by the Director.
[R307-401-8]
Status: In Compliance. The material is sufficiently damp after mining that it forms a crust
when deposited onto the piles and creates a barrier for fugitive dust.
II.B.1.l The owner/operator shall not allow visible emissions from the following conveyor emission
points to exceed the following values:
A. All conveyor transfer points - 20% opacity
B. Conveyor drop points - 20% opacity.
[R307-401-8]
Status: In Compliance. No visible emissions were observed at the time of inspection. See
the attached VEO form.
II.B.1.m The owner/operator shall not allow visible emissions from all other points to exceed 20%
opacity. [R307-401-8]
II.B.1.m.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. No opacity was observed from any point during the inspection.
8
II.B.1.n The coal fines content of the stored coal shall not exceed 5.1 percent by weight, and that of the
haul roads and pile areas shall not exceed 10 percent by weight. The coal fines content shall be
determined, if directed by the Director, using appropriate ASTM method. The coal fines content
is defined as all material passing a #200 U. S. Standard Sieve. [R307-401-8]
Status: In Compliance. See the attached sieve tests from August 27, 2023, and April 22,
2024. The sieve test Sample ID designated as ROM BC-6 is for "Stored Coal" whereas the
Sample ID designated as BC-8 is for “Haul Roads and Pile Areas." Both samples would
have 0% coal fines passing through a #200 U.S. Standard Sieve. See the attached
explanation in the email correspondence with the source.
II.B.2 Haul Roads and Fugitive Dust Sources Requirements
II.B.2.a The owner/operator shall not allow visible emissions from haul road traffic and mobile
equipment to exceed 20% opacity. [R307-401-8]
II.B.2.a.1 Visible determination for fugitive dust emissions from haul road traffic and mobile equipment
shall use procedures similar to Method 9. The normal requirement for observations to be made at
15-second intervals over a six-minute period shall not apply. Visible emissions shall be measured
at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle
and not less than 1/2 the height of the vehicle. [R307-401-8]
Status: In Compliance. No visible emissions were observed from haul road traffic or
mobile equipment at the time of inspection.
II.B.2.b To prevent visible emissions from exceeding the opacity limits listed in this AO, the
owner/operator shall apply water and/or chemical suppressant to all unpaved roads and other
unpaved operational areas that are used by mobile equipment. The owner/operator shall apply
other controls as necessary to prevent visible emissions from exceeding the opacity limits listed
in the AO. [R307-401-8]
II.B.2.b.1 Records of water treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date and time of water and/or chemical suppressant application B. Number of water and/or chemical suppressant applications made and quantity of water and/or chemical suppressant applied C. Rainfall amount received, if any [R307-401-8] Status: In Compliance. The source is familiar with the requirements of this condition and provided records with all the appropriate and relevant information. Watering records were reviewed at the time of inspection.
II.B.2.c The owner/operator shall not allow the speed of vehicles on the haul roads to exceed 25 miles per
hour. [R307-401-8]
Status: In Compliance. The source was familiar with the requirements of this condition
and confirmed they are operating accordingly. Speed limit signs are posted near the
entrance to the main operation and to the entrance to the lower mine site.
9
II.B.2.d The owner/operator shall clean all coal spills on any paved road immediately. [R307-401-8]
Status: In Compliance. No track out was observed during this inspection. The
Environmental Engineer stated that the sweeper is operated when required when coal is
spilled onto Eccles Canyon Road.
II.B.3 Emergency Engine Requirements.
II.B.3.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
Status: Not Observed. The emergency generators are only being stored without any
operational potential at this time. The engines are located at the Swen’s Canyon portion of
the mine property – about 2 miles further west on Highway 264 from Eccles Canyon. They
have not been used for any purpose in the past 12 months.
II.B.3.b The owner/operator shall perform maintenance and testing of the emergency generator engines in
accordance with the following:
A. The owner/operator shall not operate more than one (1) emergency generator engine at
any one time during maintenance and testing operations;
B. Each emergency generator shall be tested no more than once per week.
[R307-401-10]
II.B.3.b.1 To determine compliance with a rolling 12-month total and the maintenance and testing
requirements, the owner/operator shall calculate a new 12-month total by the 20th day of each
month using data from the previous 12 months. Records documenting the operation of each
emergency engine shall be kept in a log and shall include the following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage.
[40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.3.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]
Status: Not Observed. The emergency generators are only being stored without any
operational potential at this time. They have not been used for any purpose in the past 12
months. Both engines are equipped with a non-resettable hour meter.
II.B.3.c The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each emergency engine. [R307-401-8]
II.B.3.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
10
II.B.3.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-401-8]
Status: In Compliance. The source purchases only ULSD fuel for their operations. See
attached fuel invoice from Pierce Oil Company, Inc.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs have
been found to apply to this installation. This AO in no way releases the owner or operator from any liability
for compliance with all other applicable federal, state, and local regulations including UAC R307.
NSPS (Part 60) Y: Standards of Performance for Coal Preparation and Processing Plants
Status: Not Applicable. Coal operation has not been reconstructed or modified since AO
DAQE-AN10092007-03. Overall production rate, processing equipment, and storage piles have
remained consistent since that time. The source has stated that they are familiar with the requirements
of Subpart Y and will conduct appropriate testing if any applicable equipment is replaced or
reconstructed in the future. See DAQC-1331-21 for more details.
MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: Not Observed. The emergency generators are only being stored without any operational
potential at this time. They have not been used for any purpose in the past 12 months.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Emission Standards: Sulfur Content of Fuels [R307-203]
Status: In Compliance. The source uses only ultra-low sulfur diesel fuel. This area source rule is
satisfied by compliance with condition II.B.3.c.2 of the AO.
Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]
Status: In Compliance. The source is familiar with the requirements of this area source rule and
were operating accordingly at the time of inspection. No opacity was observed from any point during
the inspection.
Stationary Sources [R307-210]
Status: Not Applicable. Compliance with this area source rule is satisfied by compliance with
Federal Requirements NSPS (Part 60) Subparts Y. See Section III above for more information.
11
National Emission Standards for Hazardous Air Pollutants [R307-214]
Status: Not Applicable. Compliance with this area source rule is satisfied by compliance with
Federal Requirement MACT (Part 63) Subpart ZZZZ. See Section III above for more information.
EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Canyon Fuel Company, LLC – Skyline Mines
for the 2023 emissions reporting year. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN100920003-21, dated September 29, 2021, is provided. PTE are supplied for supplemental
purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 15125.00 N/A
Carbon Monoxide 14.10 1.70898
Nitrogen Oxides 15.37 2.0345
Particulate Matter - PM10 23.08 24.52653
Particulate Matter - PM2.5 5.19 2.63689
Sulfur Dioxide 0.07 0.01221
Volatile Organic Compounds 1.12 0.1119
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 20 3.06
Hexane (CAS #110543) 440 N/A
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement action within the past five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN100920003-21, dated
September 29, 2021, the overall status is: Out of Compliance with
Condition I.8. See Section I for more details. In compliance with all
other requirements. The facility appears to be well maintained and
operated. Required records were current and made available during
the inspection.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the regular frequency for this type of source. The mine
operates 24 hours a day, 7 days a week. The Environmental staff
works 6 am to 3 pm Monday through Friday. Check to see if
notification status for Condition I.8 was submitted.
NSR RECOMMENDATIONS: None at this time.
ATTACHMENTS: VEO form, email correspondence, rolling 12, ULSD verification,
moisture test, stockpile tonnage, sieve tests
Daniel Riddle <driddle@utah.gov>
10092 - Follow up to air quality inspection
9 messages
Daniel Riddle <driddle@utah.gov>Thu, Jul 11, 2024 at 8:53 AM
To: bwilson@wolverinefuels.com, cbrooks@wolverinefuels.com
Braden,
Thank you for meeting yesterday for your air quality inspection. As discussed, here are the records I require to complete my inspection report:
From AO DAQE-AN-100920003-21:
Condition II.B.1.a - tonnage of of coal and waste, as well as tonnage from each individual load-out for coal (June 2023 - May 2024)Condition II.B.1.b - proof that tonnage never exceeded the 4 limits in this condition (June 2023 - May 2024)
Condition II.B.1.j - proof that moisture content of material is > 4%Condition II.B.1.n - copy of recent sieve testing showing coal fines content of stored coal as well as haul roads and pile areas
Condition II.B.3.a - hours of usage for the two emergency generators for non-emergency purposes (June 2023 - May 2024)Condition II.B.3.b - logs of generator testing showing that only one emergency generator was operated for maintenance at a time and each generator was tested no more than once per
week at the maximumCondition II.B.3.c - invoice or proof of purchase of ULSD fuel
Please provide these records by July 18, 2024. Let me know if you have any questions.
Best,
Daniel
Brayden Wilson <bwilson@wolverinefuels.com>Wed, Jul 17, 2024 at 7:58 AMTo: Daniel Riddle <driddle@utah.gov>, Conner Brooks <cbrooks@wolverinefuels.com>
Good Morning Daniel,
I believe we have compiled all of the data requested to complete the inspec on. Please let me know if we missed something or if you need data that was not provided.
Condi on II.B.1.a - tonnage of of coal and waste, as well as tonnage from each individual load-out for coal (June 2023 - May 2024) - See A ached Rolling Avg.
Condi on II.B.1.b - proof that tonnage never exceeded the 4 limits in this condi on (June 2023 - May 2024) - See A ached Minesite Stockpile Tons
Condi on II.B.1.j - proof that moisture content of material is > 4% - See a ached CS- Moisture & LOB (data compiled from channel samples sent for lab analysis)
Condi on II.B.1.n - copy of recent sieve tes ng showing coal fines content of stored coal as well as haul roads and pile areas - See a ached Sieve tests
Condi on II.B.3.a - hours of usage for the two emergency generators for non-emergency purposes (June 2023 - May 2024) - See explana on below
Condi on II.B.3.b - logs of generator tes ng showing that only one emergency generator was operated for maintenance at a me and each generator was tested no more than once
per week at the maximum - See explana on below
Condi on II.B.3.c - invoice or proof of purchase of ULSD fuel - See proof of purchase a ached
In reference to the logs and hours of usage for the emergency generators, I was unable to provide this because these generators have not been used or tested for emergency or
non-emergency in the past 12 months. They have sat idle at the Swens Canyon site that we visited out of service. Please let me know if there is addi onal informa on that you need
in regard to the emergency generators.
Thank you for your me and let me know if you have any ques ons.
Thank you,
Brayden Wilson
Environmental Engineer
Skyline Mine
Wolverine Fuels, LLC
Skyline Mine
HC 35 Box 380
Helper, UT 84526
Skyline: (435) 448-2685
bwilson@WolverineFuels.com
From: Daniel Riddle <driddle@utah.gov>
Sent: Thursday, July 11, 2024 8:53 AM
To: Brayden Wilson <bwilson@wolverinefuels.com>; Conner Brooks <cbrooks@wolverinefuels.com>
Subject: 10092 - Follow up to air quality inspec on
CAUTION: This email originated from outside of Wolverine Fuels. Do not click (select) links or open attachments unless you recognize the sender and know the content issafe. Report suspicious email through the “Report Phishing” button on your email toolbar.
9/16/24, 10:03 AM State of Utah Mail - 10092 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r8526023051828179253&simpl=msg-a:r-73680594861624…1/5
[Quoted text hidden]
6 attachments
CS - Moisture % LOB.xlsx
16K
Minesite Stockpile Tons.xlsx
11K
Skyline - 2023-2024 Rolling Average.xlsx
54K
Copy of Reciept for ULSD.pdf
231K
Skyline - Sieve Crushed 8.27.23.PDF
111K
Skyline - Sieve Stockpile Uncrushed 4.18.24.PDF
111K
Daniel Riddle <driddle@utah.gov>Tu
To: Brayden Wilson <bwilson@wolverinefuels.com>Cc: Conner Brooks <cbrooks@wolverinefuels.com>
Brayden,
Apologies for the late reply. I do have a few additional questions for you regarding your records:
1) For Condition II.B.1.a - which column in the rolling 12 spreadsheet you sent me should I use for bullet A and which should I use for bullet B? None of the columns are labeled as waste mat
2) For Condition II.B.1.n - could you explain the two sieve tests you sent to me? I'm not sure which line of the test to look at and which one applies to "stored coal" (limit of 5.1% coal fines by wpile areas" (limit of 10% coal fines by weight).
3) Condition I.8 of your AO states:The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentattn.: NSR Section. [R307-401-18]
I should have included this in my original email, but this notification was technically due on March 29, 2023. If you send that an official notification now, we can mark this condition as complia
dates that the two diesel generators were fully installed and operational.
4) In regards to your engines, 40 CFR Part 60 Subpart IIII (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-60/subpart-IIII) and 40 CFR Part 63 Subpart ZZZZ (https://www.ec40/chapter-I/subchapter-C/part-63/subpart-ZZZZ?toc=1) require maintenance in accordance with manufacturer's instructions, such as maintenance of hoses, oil, belts, and filters. (Check Tabthat both engines sat idle for the past year, but has there been any other maintenance or checks on the performance of the engines?
Thanks and let me know if you have any questions,Daniel
[Quoted text hidden]
2021 ao.pdf16317K
Daniel Riddle <driddle@utah.gov>Mon, Sep 9, 2024 at 10:04 AMTo: Brayden Wilson <bwilson@wolverinefuels.com>
Cc: Conner Brooks <cbrooks@wolverinefuels.com>
Brayden - any updates here? Let me know if you're still working on obtaining this information.
[Quoted text hidden]
Brayden Wilson <bwilson@wolverinefuels.com>Mon, Sep 9, 2024 at 11:50 AMTo: Daniel Riddle <driddle@utah.gov>
Good Morning Daniel,
Apologies for the delayed response to your follow up ques ons, I have been away from the office. I will have all of the informa on by the end of the day tomorrow if that is not too
late. I do have one ques on - In regard to the maintenance of the generator engines, would you need a log of inspec ons that have taken place on the generators even though they
have been idle and stored at the Swens Canyon site or just confirma on that they are checked on rou ne inspec ons of the site?
Thank you,
Brayden Wilson
Environmental Engineer
Skyline Mine
Wolverine Fuels, LLC
Skyline Mine
HC 35 Box 380
Helper, UT 84526
Skyline: (435) 448-2685
bwilson@WolverineFuels.com
9/16/24, 10:03 AM State of Utah Mail - 10092 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r8526023051828179253&simpl=msg-a:r-73680594861624…2/5
From: Daniel Riddle <driddle@utah.gov>
Sent: Monday, September 9, 2024 10:04 AM
To: Brayden Wilson <bwilson@wolverinefuels.com>
Cc: Conner Brooks <cbrooks@wolverinefuels.com>
Subject: Re: 10092 - Follow up to air quality inspec on
[Quoted text hidden]
Daniel Riddle <driddle@utah.gov>Mon, Sep 9, 2024 at 12:47 PMTo: Brayden Wilson <bwilson@wolverinefuels.com>
I spoke with my manager about this. Are the engines set to automatically start if there was a power outage? Or could they be turned on to power operations? Or are they essentially justbeing stored without any operation potential at this time?
[Quoted text hidden]
Outlook-cid_image03K
Brayden Wilson <bwilson@wolverinefuels.com>TTo: Daniel Riddle <driddle@utah.gov>
Yes, they are essen ally just being stored without any opera onal poten al and have been for the past rolling 12 months.
See below for clarifica on on the other follow up ques ons -
1) For Condi on II.B.1.a - which column in the rolling 12 spreadsheet you sent me should I use for bullet A and which should I use for bullet B? None of the columns are labeled as waste
- For bullet A use the column E "Trucked" & Column G "Shipped" for sold tons and for bullet B use column C "Produced" for monthly produc on. On the second tab you will see t
column for Waste Material which is Column D "Shipped to Waste Rock Site From Mine". This column would be any waste material hauled from the mine in the Rolling 12 month per
2) For Condi on II.B.1.n - could you explain the two sieve tests you sent to me? I'm not sure which line of the test to look at and which one applies to "stored coal" (limit of 5.1% coal fin
roads and pile areas" (limit of 10% coal fines by weight).
- The sieve test designated in the Sample ID as ROM would be indica ve of "Stored Coal" whereas the other designated on the Sample ID as BC-6 would be indica ve of "Haul Roa
3) Condi on I.8 of your AO states:The owner/operator shall submit documenta on of the status of construc on or modifica on to the Director within 18 months from the date of this AO. This AO may become invalid icommenced within 18 months from the date of this AO or if construc on is discon nued for 18 months or more. To ensure proper credit when no fying the Director, send the documea n.: NSR Sec on. [R307-401-18]
- We will send no ce in a memo promptly to the director that the emergency generators are on site in mobile containment.
Thank you,
Brayden Wilson
Environmental Engineer
Skyline Mine
Wolverine Fuels, LLC
Skyline Mine
HC 35 Box 380
Helper, UT 84526
Skyline: (435) 448-2685
bwilson@WolverineFuels.com
From: Daniel Riddle <driddle@utah.gov>
Sent: Monday, September 9, 2024 12:47 PM
To: Brayden Wilson <bwilson@wolverinefuels.com>
Subject: Re: 10092 - Follow up to air quality inspec on
CAUTION: This email originated from outside of Wolverine Fuels. Do not click (select) links or open attachments unless you recognize the sender and know the content is safe. email through the “Report Phishing” button on your email toolbar.
9/16/24, 10:03 AM State of Utah Mail - 10092 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r8526023051828179253&simpl=msg-a:r-73680594861624…3/5
I spoke with my manager about this. Are the engines set to automatically start if there was a power outage? Or could they be turned on to power operations? Or are they essentially just beingoperation potential at this time?
On Mon, Sep 9, 2024 at 11:50 AM Brayden Wilson <bwilson@wolverinefuels.com> wrote:
Good Morning Daniel,
Apologies for the delayed response to your follow up ques ons, I have been away from the office. I will have all of the informa on by the end of the day tomorrow if that is not too lat
- In regard to the maintenance of the generator engines, would you need a log of inspec ons that have taken place on the generators even though they have been idle and stored at t
just confirma on that they are checked on rou ne inspec ons of the site?
Thank you,
Brayden Wilson
Environmental Engineer
Skyline Mine
Wolverine Fuels, LLC
[Quoted text hidden]
[Quoted text hidden]
Brayden Wilson <bwilson@wolverinefuels.com>Fri, Sep 13, 2024 at 6:40 AMTo: Daniel Riddle <driddle@utah.gov>
Good Morning Daniel,
I spoke with the lab that conducts the sieve analysis and they explained the process in greater detail. The #200 US standard sieve is a 75mm opening for very small par cle size
which I assume is why we are permi ed to test on that sieve for coal fines. If you no ce on the Sieve analysis that I sent to you, BC-8 (Haul Road & Pile Are) starts on a 2-1/2" sieve
and works down un l 0% of the material is passing through a 1/4" opening size sieve. The analysis on the BC-6 ROM (Stored Coal) starts analysis on a 4" sieve opening and works
down to 1/4" sieve to which 0% of the material passes through.
I asked the lab why we do not have analysis on a US Standard #200 sieve referenced in the approval order and they explained to me that the material size had 0% passing at 1/4"
sieve therefore it would also have 0% passing through a #200 sieve with a 75mm opening size as it is much smaller. In the approval order for condi on II.B.2.n the coal fines
content is defined as all material passing a #200 U.S. Standard Sieve. Both of these sieve analysis would be 0% passing a #200 sieve.
If we need that documented I can request that the lab notes this on the analysis report from here forward.
Thank you,
Brayden Wilson
Environmental Engineer
Skyline Mine
Wolverine Fuels, LLC
Skyline Mine
HC 35 Box 380
Helper, UT 84526
Skyline: (435) 448-2685
bwilson@WolverineFuels.com
From: Daniel Riddle <driddle@utah.gov>
Sent: Monday, September 9, 2024 12:47 PM
To: Brayden Wilson <bwilson@wolverinefuels.com>
Subject: Re: 10092 - Follow up to air quality inspec on
CAUTION: This email originated from outside of Wolverine Fuels. Do not click (select) links or open attachments unless you recognize the sender and know the content issafe. Report suspicious email through the “Report Phishing” button on your email toolbar.
I spoke with my manager about this. Are the engines set to automatically start if there was a power outage? Or could they be turned on to power operations? Or are they essentially just
being stored without any operation potential at this time?
On Mon, Sep 9, 2024 at 11:50 AM Brayden Wilson <bwilson@wolverinefuels.com> wrote:Good Morning Daniel,
9/16/24, 10:03 AM State of Utah Mail - 10092 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r8526023051828179253&simpl=msg-a:r-73680594861624…4/5
Apologies for the delayed response to your follow up ques ons, I have been away from the office. I will have all of the informa on by the end of the day tomorrow if that is not
too late. I do have one ques on - In regard to the maintenance of the generator engines, would you need a log of inspec ons that have taken place on the generators even
though they have been idle and stored at the Swens Canyon site or just confirma on that they are checked on rou ne inspec ons of the site?
Thank you,
Brayden Wilson
Environmental Engineer
Skyline Mine
Wolverine Fuels, LLC
[Quoted text hidden]
[Quoted text hidden]
Daniel Riddle <driddle@utah.gov>Mon, Sep 16, 2024 at 10:03 AM
To: Brayden Wilson <bwilson@wolverinefuels.com>
Thank you for the clarification. This email should be sufficient at this time.
[Quoted text hidden]
Outlook-cid_image03K
9/16/24, 10:03 AM State of Utah Mail - 10092 - Follow up to air quality inspection
https://mail.google.com/mail/u/0/?ik=3e54b7a6bd&view=pt&search=all&permthid=thread-a:r8526023051828179253&simpl=msg-a:r-73680594861624…5/5
MONTH PRODUCED TRUCKED SHIPPED Miscellaneous
May-23 343,290 83,934 320,657 -
Jun-23 263,259 76,435 171,575 38,184
Jul-23 378,287 94,482 119,875 10,826
Aug-23 162,218 41,900 174,257 7,897
Sep-23 87,623 66,818 179,471 8,952
Oct-23 315,503 107,583 174,844 3,152
Nov-23 34,724 108,620 79,559 296
Dec-23 42,430 60,536 33,382 16,170
Jan-24 330,591 98,341 62,222 11,585
Feb-24 315,548 150,281 74,094 17
Mar-24 328,192 213,038 56,059
Apr-24 96,883 98,055 33,858
May-24 64,474 111,120 59,725
Jun-24 83,033 178,113 70,239
THROUGHPUT FOR CANYON FUEL COMPANY, L
For May 2023 TO June 2024
TRUCKED
IN OUT OUT
Last 12 Month Last 12 Month Last 12 Month
Rolling Period Rolling Period Rolling Period
343,290 320,657 83,934
606,549 492,232 198,553
984,836 612,107 303,861
1,147,054 786,364 353,658
1,234,677 965,835 429,428
1,550,180 1,140,679 540,163
1,584,904 1,220,238 649,079
1,627,334 1,253,620 725,785
1,957,925 1,315,842 835,711
2,273,473 1,389,936 986,009
2,601,665 1,445,995 1,199,047
2,698,548 1,479,853 1,297,102
2,763,022 1,539,578 1,408,222
2,846,055 1,609,817 1,586,335
LLC/SKYLINE MINE
Month
High Ash
Coal to
Wash Plant
from Mine
Shipped from
Waste Rock Site
Shipped to
Waste
Rock Site
from Mine
Coal to Dugout
Canyon Mine Total
May-23 - - - - -
Jun-23 38,184.00 - - - 38,184.00
Jul-23 7,437.00 3,389.00 - - 10,826.00
Aug-23 - 7,897.00 - - 7,897.00
Sep-23 - 8,951.70 - - 8,951.70
Oct-23 - 3,152.00 - - 3,152.00
Nov-23 296.00 5,256.00 - - 5,552.00
Dec-23 16,170.00 - - - 16,170.00
Jan-24 11,585.00 - - - 11,585.00
Feb-24 - - 17.26 17.26
Mar-24 - - -
Apr-24 - - -
May-24 - - -
Jun-24 - - -
73,672.00 28,645.70 - 17.26 - 102,334.96
Date Taken Seam Total Moisture (%)Eq Moisture (%)
3-Apr-23 LOB 6.82 5.80
28-Jun-23 LOB 5.88 5.10
15-Jan-24 LOB 5.69 4.90
26-Jan-24 LOB 6.02 5.20
11-Mar-24 LOB 6.11 5.30
18-Mar-24 LOB 6.01 5.20
1-Apr-24 LOB 5.52 4.90
2-May-24 LOB 6.04 5.30
14-May-24 LOB 6.19 5.60
23-May-24 LOB 5.15 4.80
12-Jun-24 LOB 7.42 6.10
COAL MOISTURE % FOR CANYON FUEL COMPANY, LLC/SKYLINE MINE
For May 2023 TO Present
Upper Stockpile
Tonnage
Lower Stockpile
Tonnage
Emergency
Storage Pile
Tonnage
May-23 3,781.09 16,000.00 -
Jun-23 35,624.81 13,000.00 -
Jul-23 222,273.57 600 -
Aug-23 211,571.18 3,200.00 -
Sep-23 68,296.72 1,500.00 -
Oct-23 136,165.42 4,500.00 -
Nov-23 26,673.97 7,000.00 -
Dec-23 27,127.26 16,000.00 -
Jan-24 189,889.82 16,000.00 -
Feb-24 289,599.18 16,000.00 -
Mar-24 357,682.57 16,000.00 -
Apr-24 315,828.27 16,000.00 -
May-24 208,687.11 16,000.00 -
Jun-24 34,998.26 16,000.00 -
END OF MONTH STOCKPILE TONNAGE FOR CANYON FUEL COMPANY
For May 2023 TO June 2024
TOTALS
19,781.09
48,624.81
222,873.57
214,771.18
69,796.72
140,665.42
33,673.97
43,127.26
205,889.82
305,599.18
373,682.57
331,828.27
224,687.11
50,998.26
Y, LLC/SKYLINE MINE