DAQ-2024-011861

GENTRY MOUNTAIN MINING, LLC
P.O. BOX 300 Office [phone]
Huntington, UT 84528
December 3, 2024
Chad Gilgen, Manager
Utah Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Re: Compliance Advisory DAQC-1126-24
Dear Mr. Gilgen:
Enclosed is the response to the Compliance Advisory dated November 12, 2024, which I
received on November 20, 2024. The enclosed response is a report of a performance test
conducted in accordance with Section 60.255(b)(2) as referenced in the Compliance Advisory.
If you have any questions regarding this matter, please contact me.
Sincerely,
Miles Stephens
Mine Engineer
Office: 435-687-2178
Mobile: [phone]
[e-mail]
Enclosure(s)
Cc: COP Development Company, LLC
REVIEWED
Initials:DDR Date:12/4/2024 Compliance Status: Response to CA File #: 10240 (B1)
OPACITY MONITORING AT THE BEAR CANYON MINE
AO - DAQE-AN102400006-19
NOVEMBER 2024
This report presents the results of visible emissions observations performed at the Bear Canyon Mine located
at 5550 W. Bear Canyon Road, Huntington, UT 84528. This facility is operated by Gentry Mountain Mining,
LLC. The observations were performed in compliance with the minor source Approval Order
DAQE-AN102400006-19 (AO) issued by the Utah Division of Air Quality. The observations were performed by
Miles Stephens of Gentry Mountain Mining, LLC, an EPA Method 9 Certified reader (See Attachment 3). The
opacity readings were conducted intermittently between 11/11/24 and 11/22/24.
The Bear Canyon Mine is subject to Section 60.255(b)(2) of Subpart Y of the Environmental Protection
Agency’s New Source Performance Standards (NSPS) for new and modified stationary sources of air
pollutants, which applies to facilities that commenced construction, reconstruction, or modification after April,
2008. This Section requires that performance tests be conducted periodically during normal operation of the
mine to demonstrate compliance with the applicable emissions standard stated in the AO, with the frequency of
the tests dependent on the results of the most recent performance test.
The AO for Bear Canyon was modified to include additional equipment (Dry Coal Separator) and was
approved on October 24, 2019. The dry coal separator has yet to be commissioned, and therefore was not
included in this observation. Method 9 visible emissions observations were performed according to the test
method and procedures outlined in Section 60.257(a)(1)-(3) and the approved AO.
Bear Canyon Mine Emissions Observation Performance Method
The mine facilities include transporting the coal from underground via 4 surface conveyor belts that deliver
run-of-mine (ROM) coal through a tipple processing facility which includes sorting into multiple stockpiles
before being loaded into haul trucks.
Conveyor Belt #4 transports the coal from underground to the surface and into a fully enclosed storage bin
after which the ROM is fed onto Conveyor belt #3. Since this transfer point is fully enclosed, it meets
compliance per Section 60.255(c). The coal is transported down the canyon from the storage bin via
Conveyors 3, 2, and 1, after which point processing begins. The coal can be crushed and sorted into 4 distinct
piles: High Ash (Pile 4), Low Ash (Pile 1), slack coal, or lump coal. Under normal operations, the coal is most
commonly only sorted between Pile 4 and Pile 1, and only occasionally sorted into slack or lump piles. During
this observation, only Pile 4, Pile 1 and slack coal were being produced. Although no lump coal was being
produced, the lump coal screenage crusher was turned on long enough to perform an emissions evaluation.
There were a total of 14 observation points observed. These emission sources observed (identified as A thru
N) as well as the locations where each observation was conducted (identified as 1 thru 14) are shown on
Figures 1-3. A summary table comparing the results with opacity limits per the approved AO are given in Table
1 and a more detailed tabulation of the field observations is given in Table 2. The observation field sheets are
included in Attachment 1, and the observer’s Method 9 certificate is included in Attachment 2.
FIGURE 1 - Conveyor Transfer Points from Underground to Surface Processing (Observed 11/11/24)
FIGURE 2 - Coal Processing, Coal Storage, Truck Loading (Observed 11/15, 11/19, 11/21, 11/22)
FIGURE 3 - Coal Truck Haul Roads (Observed 11/21/24).
Table 1 - Bear Canyon Mine Opacity Limits and Highest Average Observed Opacity
Conveyor
Transfer Points
20 0 1 Conveyor 3 to 2 transfer point.
20 0 2 Conveyor 2 to 1 transfer point
20 0 3 Conveyor 1 to Upper Screen
Tipple
Processing
20 0 4 Upper Screen
20 0 5 Gundlach Crusher
20 0 6 Lower Screen
20 2.29 12 Lump Screenage Crusher
Coal Storage
Pad
20 0 7 ROM Conveyor drop to Pile #4
20 0 8 ROM Conveyor drop to Slack Pile
20 0 9 ROM Conveyor drop to Pile #1
Truck Loading
Points
20 0.21 10 Coal loadout #4
20 0.21 11 Coal loadout #1
Haul Roads 20 0 13 Haul road location #1
20 0 14 Haul road location #2
Emission
Sources
Opacity Limits
per AO
DAQE-AN1024
00006-19 (%)
Observed
Opacity,
Highest
Average (%)
Observation
Point Notes
Table 2 - Tabulation Summary of Field Sheet Observations and Average Opacity.
Facility Observation
Point Location
Date Minutes
Interval
Average
Opacity (%)
Notes
Bear Canyon Mine
Conveyor 3-2
Transfer 11/11/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
A 7-12 0
13-18 0
19-24 0
25-30 0
B
Conveyor 2-1
Transfer 11/11/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
C
Conveyor 1
Transfer to
Upper
Screen
11/11/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
D
Upper
Screen 11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
E
Gundlach
Crusher 11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
F
Lower
Screen 11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
G
Conveyor
drop to Pile
#4
11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
H
Conveyor
drop to Slack
Pile
11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
I
Conveyor
drop to Pile
#1
11/15/24
1-6 0 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 0
13-18 0
19-24 0
25-30 0
L
Lump
Screenage
Crusher
11/19/24
1-6 2.08 Observations stopped after 30
minutes because all 6-minute
averages were equal to or less
than half of the opacity limit.
7-12 1.67
13-18 2.29
19-24 1.88
25-30 1.46
K
Truck
Loadout #1 11/21/24 1-6 0
Observed 2 trucks being loaded
(total of 4 trailers) during two
separate 6-minute intervals.7-12 0.21
J
Truck
Loadout #4 11/22/24 1-6 0.21
Observed 2 trucks being loaded
(total of 4 trailers) during two
separate 6-minute intervals.7-12 0.21
M
Haul Road
Location #1 11/21/24
1 0 Observed 6 passes after the
truck left Loadout #1.2 0
3 0
4 0
5 0
0
N
Haul Road
Location #2 11/21/24
1 0 Observed 6 passes after the
truck left the scales.2 0
3 0
4 0
5 0
0
Pass #
6
Pass #
6
Conclusions and Recommendations
Observed visible emissions from a viewed sources were less than the applicable limit and the Bear Canyon
Mine is in compliance with applicable opacity limits. Based on the requirements given in Section 60.255(b)(2)
of Subpart Y, the next performance test is due within 12 calendar months of the date that this performance test
was completed.
ATTACHMENT 1
Opacity Observation Field Sheets
ATTACHMENT 2
Method 9 Certification
Mi
l
e
s

S
t
e
p
h
e
n
s
Is
s
u
e
d
:

0
9
/
3
0
/
2
0
2
4

Ex
p
i
r
e
s
:

0
3
/
3
0
/
2
0
2
5

Miles Stephens
Certification Date: September 30, 2024
Expiration Date: March 30, 2025 AeroMet Instructor: Steve Mumma