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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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Compliance with opacity standards shall be demonstrated according to <br />§ 60.11. <br />Source is in compliance with the requirements of Subpart Y, as well as most of the <br />General Provisions of Subpart A. No opacity above the applicable thresholds was <br />observed from any point during the inspection, and the source accurately records <br />all startups, shutdowns, and malfunctions as necessary. No concealment of <br />emissions has been observed. However, opacity was observed during the loading <br />of the rock dust silo, and there was significant buildup of rock dust around the <br />area of the baghouse associated with that unit. The rock dust loader at the time of <br />the inspection did not appear to determine the psi loading rate of the silo based on <br />the silo/baghouse recommended parameters, but instead based it solely on the <br />capabilities of the truck. Similarly, the source did not report performing regular <br />maintenance on the silo baghouse. Following the inspection, it was established <br />that the opacity was the result of an incorrectly installed access door gasket, <br />which was replaced immediately following the inspection. <br />As opacity was observed at the time of the inspection and there appeared to be a <br />significant amount of buildup around the baghouse, it was determined that the <br />source was not operating in a manner consistent with good air pollution control <br />practices for minimizing emissions, and is thus NOT in compliance with paragraph <br />a. of this Condition. <br />10. Transfer points shall be enclosed to minimize emissions of particulate matter. <br />All transfer points and conveyors are enclosed as required. Source is in <br />compliance. <br />11. Public access shall be precluded, as per Mountain Coal Company's January 26, 2010 <br />letter to Mr. Jon Torizzo, in all areas within the modeling receptor exclusion zone as <br />submitted with the modeling with the application. Fenced areas shall be posted with no <br />trespassing signs. <br />The facility is fenced in with no trespassing signs posted to preclude public <br />access. Source is in compliance. <br />12. This source shall be limited to the maximum production rates and emissions controls as <br />listed in Attachment A. Daily records of the actual production rates shall be maintained by <br />the applicant and made available to the Division for inspection upon request. <br />As listed above under Conditions 6 and 7, the source has demonstrated <br />compliance with all prod uctiontth rough put and emissions limits as listed in <br />Attachment A. Source is in compliance. <br />13. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at <br />any such time that this source becomes major solely by virtue of a relaxation in any <br />permit condition. Any relaxation that increases the potential to emit above the applicable <br />PSD threshold will require a full PSD review of the source as though construction had not <br />yet commenced on the source. The source shall not exceed the PSD threshold until a <br />PSD permit is granted. (Reference: Regulation No.3, Part D, Section VI.13.4.) <br />There have been no relaxations in permit requirements. However, as the source <br />may have significant emissions of VOCs which have yet to be more precisely <br />quantified, the source may be subject to PSD review following the coming <br />enforcement action and subsequent permit modifications. <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 20 of 30 <br />
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