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concealment of emissions has been observed. The source also appears to be operating and <br />maintaining all points in a manner consistent with good air pollution control practices for <br />minimizing emissions. Source is in compliance with 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 compliance. <br />IL . Public access shall be precluded, as per Mountain Coal Company's January 26, 2010 letter to Mr. Jon <br />Torizzo, in all areas within the modeling receptor exclusion zone as submitted with the modeling with the <br />application. Fenced areas shall be posted with no trespassing signs. <br />The facility's main operations area 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 listed in <br />Attachment A. Daily records of the actual production rates shall be maintained by the applicant and made <br />available to the Division for inspection upon request. <br />As listed above under Conditions 6 and 7, the source has demonstrated compliance with all <br />production, throughput, and emissions limits as listed in Attachment A. Source is in compliance. <br />13. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time <br />that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation <br />that increases the potential to emit above the applicable PSD threshold will require a full PSD review of <br />the source as though construction had not yet commenced on the source. The source shall not exceed the <br />PSD threshold until a PSD permit is granted. (Reference: Regulation No.3, Part D, Section VL13.4.) <br />There have been no relaxations in permit requirements which would trigger PSD requirements for <br />PM emissions. It is unknown when the facility may have exceeded the 250 tpy VOC emissions PSD <br />trigger threshold (presuming these emissions are considered point source rather than fugitive). It <br />would be reasonable to estimate that as the underground mine workings expand, and old "sealed" <br />panels continue to offgas, VOC emissions may have increased above the levels originally exhausted <br />during the first several years of mine operation. However, if not originally operating above the 250 <br />tpy value, the source would trigger PSD review only after either: <br />a. Becoming a major stationary source under PSD (i.e. exceeding 250 tpy of any pollutant) <br />and then commencing a modification which resulted in an increase in emissions above the <br />applicable significance threshold, or <br />b. Commencing a modification which resulted in an increase in emissions above the PSD <br />major stationary source threshold (250 tpy). <br />As the Division historically did not require permit modifications for expanding underground <br />workings (as permits primarily involved surface operations' emissions), and there is no historic <br />data regarding quantified yearly methane or VOC emissions, there is additional uncertainty <br />regarding when a modification may have occurred at the mine which would have triggered PSD <br />review. <br />Due to these uncertainties and based on the information currently available, although it appears <br />MCC is operating with VOC emissions above 250 tpy, the inspector does not have adequate <br />2015 Inspection m <br />IF <br />0510015-INSP-2015 Page 17 of 37 <br />