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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
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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 three main stockpiles — The source uses a Division -approved method of <br />calculating dozer hours of operation based on historical hours per coal production (see August 2011 <br />O&M Plan Version 02). The highest daily hours of operation on the ROM stockpiles was 50 hours, <br />occurring on 10/5/2014. This value is below the 60 hours/day limit. <br />Maintenance activities on silo stockpiles — The source uses a Division -approved method of <br />calculating dozer hours of operation based on historical hours per coal production (see August 2011 <br />O&M Plan — Version 02). The highest daily `hours of operation' for the silo stockpiles was 9 hours, <br />occurring on 4/13/2014. This value is below the 40 hours/day limit. <br />Maintenance activities on refuse stockpiles — The source uses a Division -approved method of <br />calculating dozer hours of operation, based on historical hours per coal production (see August <br />2011 O&M Plan — Version 02). The highest daily `hours of operation' for the refuse stockpiles was <br />23 hours, occurring on 3/14/2013. This value is below the 75 hours/day limit. <br />It was verified for all `dozer hour limits' that the source is utilizing the calculation methodology <br />outlined in the approved O&M Plan. At the time of the 2012 inspection, the source explained that <br />this approved methodology provides a conservative estimate of actual dozer hours of operation. <br />Attachment A Limits: <br />-Point 014 and Point 016: There is a `truck hauling of coal' limit of 1,000,000 tpy (Point <br />014) from the storage stockpile and emergency stockpile. There is also a truck haulage limit of coal <br />from the ROM stockpile of 500,000 tpy (Point 016). During the inspection period, the source <br />trucked coal during Feb 2014 from the facility. This coal was trucked from silos, which are <br />included under the 1,000,000 tpy limit of Point 014. There was no truck hauling of coal from the <br />ROM stockpile during the inspection period. The source is in compliance with truck haulage limits <br />listed in Attachment A. <br />-Point 019: Throughput of ventilation air shall not exceed 3,000,000 cubic feet per minute. <br />Shaft #2 fans shall be restricted to one (1) fan operating at any time. The source confirmed during <br />the inspection that only one (1) Shaft #2 fan is operated at a time. Provided records also verified <br />that the source calculates throughput of ventilation air on a monthly and rolling 12 -month average, <br />with the highest monthly average of 1,537,730 acfm occurring during the month of Dec 2013, and <br />the highest rolling 12 -month average of 1,411,029 acfm occurring during the 12 -month period <br />ending Apr 2014. The source appears to typically operate with a rolling 12 -month average <br />ventilation air throughput around 1,350,000 actin. These values are below the permitted limits for <br />this AIRS Pt. <br />The source is in compliance with all throughput and production limits listed in this condition. <br />Emissions of air pollutants shall not exceed the following limitations, and the specific limits in <br />Attachment A (as calculated in the Division's preliminary analysis): (Reference: Regulation 3, Part B, III. <br />A. 4) <br />Particulate Matter: 68.8 tons per year. <br />PM 10 (Particulate Matter<10 µm): 60.3 ton per year. <br />Particulate Matter - Fugitive: 85.4 tons per year. <br />PM 10 (Particulate Matter<10 µm) - Fugitive: 27.9 tons per year. <br />2015 Inspection �'4'f <br />0510015-INSP-2015 Page 12 of 37 <br />
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