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2017-10-23_GENERAL DOCUMENTS - C1980007
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2017-10-23_GENERAL DOCUMENTS - C1980007
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Last modified
10/24/2017 7:12:12 AM
Creation date
10/24/2017 6:56:38 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
General Documents
Doc Date
10/23/2017
Doc Name
Compliant and Request for Inspection Over Failure of West Elk
From
Wild Earth Gurdians
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
LDS
Media Type
D
Archive
No
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Maintenance activities on refuse stockpiles — The source uses a Division -approved <br />method of calculating dozer hours of operation, based on historical hours per coal <br />production (see August 2011 O&M Plan — Version 02). The highest daily `hours of <br />operation' for the refuse stockpiles was 21 hours, occurring on 12/2/2011. This <br />value is below the 75 hours/day limit. <br />It was verified for all 'dozer hour limits' that the source is utilizing the calculation <br />methodology outlined in the approved O&M Plan. At the time of the inspection, the <br />source stated that this approved methodology provides a conservative estimate of <br />actual dozer hours of operation. <br />Attachment A Limits: <br />-Point 014 and Point 016: There is a 'truck hauling of coal' limit of <br />1,000,000 tpy (Point 014) from the storage stockpile and emergency stockpile. <br />There is also a truck haulage limit of coal from the ROM stockpile of 500,000 tpy <br />(Point 016). The source has not trucked any coal from the facility since September, <br />2010. Prior to ceasing that activity, the source's largest trucking of coal from ROM <br />stockpile was 85,629 tpy. The source also trucked material from silos (maximum <br />rolling 12 -month total of 423,728 tpy on Jan 2010), but it is unclear if this silo <br />material trucking is for Point 014, or whether this activity is limited in the permit. In <br />any case, it appears that both values are below the limits associated with truck <br />haulage as listed in Attachment A. <br />-Point 019: Throughput of ventilation air shall not exceed 3,000,000 cubic <br />feet per minute. Shaft #2 fans shall be restricted to one (1) fan operating at any <br />time. The source confirmed during the inspection that only one (1) Shaft #2 fan is <br />operated at a time. Provided records also verified that the source calculates <br />throughput of ventilation air on a rolling 12 -month average, with the highest <br />average of 1,899,163 cubic feet per minute occurring during the period of Feb 2009 - <br />Jan 2010. Since that time period, the source appears to operate with a rolling 12 - <br />month average ventilation air throughput around 1,350,000 actual cubic feet per <br />minute. These values are below the permitted limits for this Point. <br />Source is in compliance with all throughput and production limits listed in this <br />Condition. <br />7. Emissions of air pollutants shall not exceed the following limitations, and the specific <br />limits in Attachment A (as calculated in the Division's preliminary analysis): (Reference: <br />Regulation 3, Part B, III. A. 4) <br />Particulate Matter: 68.8 tons per year. <br />PM10 (Particulate Matter<10 µm): 60.3 ton per year. <br />Particulate Matter - Fugitive: 85.4 tons per year. <br />PM10 (Particulate Matter<10 jm) - Fugitive: 27.9 tons per year. <br />Compliance with the yearly emission limits shall be determined on a rolling <br />twelve (12) month total. <br />Notes: For AIRS IDs 051/0015/011, 012, 013, 019 & 020, Coal Processing <br />System: The permit holder shall calculate emissions as defined in <br />Attachment A, based on daily production and keep a compliance record <br />on site in order to demonstrate compliance with the above emission <br />limitations. Annual emissions shall be calculated based on the previous <br />twelve (12) months' emission data. These calculated annual emissions <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 15 of 30 <br />
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