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-Point 016: Emissions from hauling of coal from the ROM storage pile are limited <br />by the source following the fugitive dust control plan, and not exceeding the truck <br />haulage limit of 500,000 tpy. The source is limited to PM and PM10 emissions from <br />these activities of 9.2 tpy and 2.5 tpy respectively. Before ceasing this activity in <br />Sept 2010, the source's highest 12 -month rolling total calculated emissions were <br />1.58 tpy and 0.43 tpy for PM and PM10 respectively. These values are below <br />permitted limits for this point. <br />-Point 019: Coal mine ventilation shaft emissions are limited to 49.2 tpy for both <br />PM and PM10 (all PM exiting mine shafts is conservatively estimated to be PM10). <br />The source has operated with ventilation air throughput below the permit limit of <br />3,000,000 cubic feet per minute, and reported actual emissions to be a maximum of <br />31.13 tpy during the 12 -month rolling average period from Feb 2009 — Jan 2010. All <br />values are below permitted limits for this point. <br />-Point 020: Coal prep plant process equipment emissions are limited by all <br />processes being enclosed, and by a 4,500,000 tpy processing rate limit. <br />Associated emissions from this activity are limited to 3.3 tpy and 1.7 tpy for PM <br />and PM10 respectively. The highest reported emissions from the Coal prep plant <br />were 1.88 tpy and 0.88 tpy for PM and PM10 respectively, which occurred during <br />the 12 -month rolling total period from July 2011 -June 2012. These values are <br />below the permitted limits for this point. <br />The source also provided coal moisture values, as recorded monthly and on a <br />rolling 12 -month total. For any given month during the reporting period (2010 -Sept <br />2012), coal moisture remained above 7%, and did not drop below 10.2% for any <br />given month. This coal moisture limit was included in the source's previous <br />material handling permit (95GU508-1), and is part of the fugitive dust control plan, <br />but has not been incorporated into the current facility -wide permit 09GU1382. <br />However, as Attachment A lists that one of the main emissions controls applied <br />throughout the process is the natural moisture content of the coal, the fact that the <br />moisture content has remained above 10.2% demonstrates that the source is in <br />compliance with this control requirement. Similarly, Attachment A requires the <br />source to follow the approved dust control plan, which includes the >7% moisture <br />content requirement (see attached). <br />Along with verifying compliance with emission limits, the inspector verified that all <br />calculations were being performed on a rolling 12 -month total as required, and <br />using the emissions factors listed in Attachment A. Therefore, as listed <br />individually above, the source is in compliance with all emissions limitations in <br />this Condition. <br />8. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation <br />No. 3, Part A, Section II.C.) <br />a. Annually whenever a significant increase in emissions occurs as follows: <br />For any criteria pollutant: <br />For sources emitting less than 100 tons per year, a change in actual emissions of <br />five tons per year or more, above the level reported on the last APEN submitted; <br />or <br />A change in actual emissions, above the level reported on the last APEN <br />submitted, of 50 pounds of lead <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 17 of 30 <br />