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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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requirements of condition no 6 listed above. The operating and maintenance plan shall <br />commence at startup. (Reference: Regulation No. 3, Part B, Section III.G.7. <br />Source submitted an operating and maintenance plan for the engine along with all <br />other self certification documents in August of 2010. The O&M Plan was not <br />appropriately routed to the O&M Plan coordinator for approval at that time, but has <br />been provided to him for review following this inspection. With the addition of a <br />visible emissions check in the 'Monitoring Frequency' section of the submitted <br />plan, the submitted O&M Plan will be approved. Source has been following all <br />parts of the O&M Plan as required, and reported that there are no visible emissions <br />from the unit during operation. Thus the upcoming addition to the plan involving <br />visible emissions checks/recordings would not have had an effect on operations <br />up to this point. Source is in compliance. <br />8. These sources shall be limited to a maximum fuel use rate, and maximum hours of <br />operation, as listed below and all other activities, operational rates and numbers of <br />equipment as stated in the application. Annual records of the actual consumption rate <br />shall be maintained by the applicant and made available to the Division for inspection <br />upon request. (Reference: Regulation No. 3, Part B, Section II.A.4.) <br />Consumption of #2, Low Sulfur Diesel fuel shall not exceed 75,000 gallons/year. <br />Hours of operation shall not exceed 500 hours per year. <br />The unit is rarely used, operated during 1 hour monthly tests and during <br />emergencies only. Source reported that the unit operated in 2012 (through <br />August) for a total of 7 hours, and only 5 hours during 2011. During 2010, the unit <br />operated for 21 hours, as this was the time period that initial startup and testing <br />was performed. The source currently tracks diesel deliveries to the tank only, <br />rather than consumption by the unit during any given year. This would have <br />normally been addressed earlier during the approval of the O&M Plan, but this plan <br />was not routed correctly at the Division and this discrepancy was not noticed until <br />this inspection. Because the facility has only had 1,600 gallons of diesel fuel <br />delivered to the facility since 2010 (startup of the unit), they have demonstrated <br />compliance with the requirements of this condition. Diesel records verified <br />compliance with low sulfur diesel requirements. Source is in compliance. <br />The inspector notified the facility of the record-keeping discrepancy, and the <br />source re -submitted the Emergency Fan Generator Emissions spreadsheet on <br />January 11, 2013. This new format was also attached to the previously submitted <br />O&M Plan for approval. <br />9. 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 />For any non -criteria reportable pollutant: <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 23 of 30 <br />
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