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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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38.4 tpy and 11.4 tpy respectively. As the source has demonstrated compliance with the control <br />plan, dozer hours of operation, and has not exceeded production/material handling limits, they <br />have demonstrated compliance with these fugitive emissions limits. <br />-Point 016: Emissions from hauling of coal from the ROM storage pile are limited by the source <br />following the fugitive dust control plan, and not exceeding the truck haulage limit of 500,000 tpy. <br />The source is limited to PM and PM10 emissions from these activities of 9.2 tpy and 2.5 tpy <br />respectively. The source ceased most of these truck hauling activities in Sept 2010, with the only <br />hauling occurring during this compliance period in Feb 2014 with 693 tons of material hauled from <br />silos. This corresponded to PM and PM10 emissions of 0.00 tons from this limited activity, below <br />permitted limits for this point. <br />-Point 019: Coal mine ventilation shaft emissions are limited to 49.2 tpy for both PM and PM10 (all <br />PM exiting the mine shafts is conservatively estimated to be PM10). The source has operated with <br />ventilation air throughput below the permit limit of 3,000,000 cubic feet per minute, and reported <br />actual emissions to be a maximum of 23.13 tpy during the 12 -month rolling average period ending <br />Apr 2014. All values are below permitted limits for this point. <br />-Point 020: Coal prep plant process equipment emissions are limited by all processes being <br />enclosed, and by a 4,500,000 tpy processing rate limit. Associated emissions from this activity are <br />limited to 3.3 tpy and 1.7 tpy for PM and PM10 respectively. The highest reported emissions from <br />the Coal prep plant were 1.62 tpy and 0.76 tpy for PM and PM10 respectively, which occurred <br />during the 12 -month rolling total period ending Sept 2012. These values are below the permitted <br />limits for this point. <br />The source also provided coal moisture values, as recorded monthly and on a rolling 12 -month <br />total. For any given month during the reporting period, coal moisture remained above 7%, and did <br />not drop below 10.4% for any given month. This coal moisture limit was included in the source's <br />previous material handling permit (95GU508-1), and is part of the fugitive dust control plan, but <br />has not been incorporated into the current facility -wide permit 09GU1382. However, as <br />Attachment A lists that one of the main emissions controls applied throughout the process is the <br />natural moisture content of the coal, the fact that the moisture content has remained above 10.4% <br />demonstrates that the source is in compliance with this control requirement. Similarly, Attachment <br />A requires the 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 calculations <br />were being performed on a rolling 12 -month total as required, and using the emissions factors listed <br />in Attachment A. Therefore, as listed individually above, the source is in compliance with all <br />emissions limits in this condition. <br />A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, <br />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 five tons per <br />year or more, above the level reported on the last APEN submitted; or <br />2015 Inspectionlaw <br />0510015-INSP-2015 Page 14 of 37 <br />
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