2017-10-23_GENERAL DOCUMENTS - C1980007

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SOURCE COMPLIANCE HISTORY 2009 — Division inspection determined source was out of compliance with the Operating & Maintenance plan requirements of the permit. Enforcement action was not recommended for this compliance issue. This is because the requirement to develop an O&M Plan had not been included in any previous Initial Approval Permits prior to being incorporated into the Final Approval permit that was applicable during the 2009 inspection. The Division and source worked together to develop an approved plan and no further action was required. 2006 — Division inspection listed source as in compliance. 2003 — Division inspection listed source as in compliance. There is no prior enforcement history for this facility. NSPS/NESHAP/MACT APPLICABILITY • The source is subject to NSPS Subpart Y — Standards of Performance for Coal Preparation Plants. • The source is subject to NSPS Subpart IIII — Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. • The source is also subject to the mandatory greenhouse gas reporting requirements of 40 CFR Part 98, Subpart C — General Stationary Fuel Combustion, and Subpart FF — Underground Coal Mines. The Administrator of these Regulations is the US EPA, and compliance with Subpart C and Subpart FF are not within the scope of this inspection. MALFUNCTION REPORT REVIEW The source reported a 12 minute malfunction which occurred on 10/20/2010, shortly after beginning operation of their prep plant. Details of the malfunction, as copied from the Division's compliance tracking program, are as follows: "Off-site transport of visible dust. MCC recently completed construction of a new Coal Preparation Plant (CPP). The CPP uses a wet process to remove non -coal rock usually associated with coal mining. Trial runs have been occurring over the last month. Opacity observations were documented and no visible emissions were observed. As is typical in starting a new plant, the CPP shut down for almost a week in order to make some major modifications to improve efficiency. The CPP was restarted on the afternoon of 10/20/10. Soon after startup, MCC personnel observed excessive dust coming from a stack tube at the final product stockpile. Slow moving winds carried dust off MCC property and onto the adjacent highway. MCC immediately discerned the cause of the malfunction and worked quickly to stop the emissions. MCC determined that an atypical product was introduced into the CPP system. This atypical product was created by pre -segregating the coal before sending it to the CPP, which MCC normally does not do. The result was a finer product and it had dried considerably while the CPP was down. In the CPP process the fines are removed before the wet process and sent directly to the final product stockpile. The dry atypical product dispersed into the atmosphere when exiting the stack tube. MCC remedied the situation by applying a hose to the fines conveyor which immediately stopped the emissions. MCC is installing a water bar on the fines conveyor." This malfunction was approved by the Division on 10/28/2010, and no further action is necessary. COMPLIANCE ASSISTANCE Source was requested to submit APENs for NSPS Subpart IIII applicable emergency generators that were discovered during this inspection, as well as for the rock dust silo. The source was also informed of all other outstanding compliance issues, and that the Division will offer assistance in coming back into compliance prior to the start of the enforcement process. 2012 Air Pollution Inspection 0510015-INSP-2012.docx Page 10 of 30