Laserfiche WebLink
information to determine whether a PSD violation occurred. Without adequate evidence to suggest <br />the contrary, the source is determined to be in compliance with this condition. <br />14. Operating Permit (OP) requirements shall apply to this source at any such time that this source becomes <br />major solely by virtue of a relaxation in any permit limitation. Any relaxation that increases the potential <br />to emit above the applicable OP threshold shall require submittal of and issuance of an operating permit, <br />under Regulation No. 3, Part C. <br />There have been no relaxations in permit requirements. Although current data and information <br />does not allow the inspector to adequately determine whether the facility is operating above 250 tpy <br />(see Condition 13 above), the data consistently shows the facility is operating with VOC emissions <br />above the 100 tpy Title V Operating Permit threshold. This determination is made presuming that <br />the ventilation emissions are considered point source, rather than fugitive, as they are being <br />released from underground activities, collected in an air handling system, and exhausted from a <br />stack (see Conclusion section for additional fugitive vs. point source discussion). <br />The source submitted a Title V application in June 2012 due to their GHG Emissions and EPA's <br />application of the "Tailoring Rule". However, the Supreme Court later determined in June 2014 <br />that the Tailoring Rule's GHG emissions thresholds and corresponding Title V permit <br />requirements should not apply to facilities that are considered major sources solely due to GHGs. <br />Following this ruling, MCC cancelled their Title V application, which notably did not include <br />reporting VOC emissions. Based on the information available, the inspector has determined that <br />the source is subject to Title V permitting for VOC emissions. Therefore, as the source has not <br />submitted a Title V application that accurately reports their VOC emissions and has withdrawn <br />their 2012 application, the source is NOT in compliance with the requirements of Regulation 3, Part <br />C as referenced in this condition. <br />15. The applicant shall follow the most current operating and maintenance plan and record keeping format <br />approved by the Division in order to demonstrate compliance on an ongoing basis with the requirements <br />of this permit. (Reference: Regulation No. 3, Part B, Section III.G.7.) <br />The source is following the most recent O&M Plan, which was submitted 8/25/2011 and approved <br />by the Division on 10/14/2011. The O&M Plan primarily includes that the source must conduct and <br />record inspections and maintenance on process equipment, dust control enclosures, and water <br />systems as recommended by the manufacturer. MCC regularly monitors dust control systems and <br />performs maintenance as required. There were no visible emissions observed during the inspection. <br />Without evidence to suggest the contrary, the source is in compliance. <br />16. Issuance of this permit cancels the permits contained in the following table. AIRS IDs are not cancelled. <br />Permit Number <br />95GU508-1 <br />95GU508-2 <br />95GU508-3 <br />95GU508-4 <br />95GU508-5 <br />96GU736 <br />99GUO832 <br />No action required by the source for this Condition. Source is in compliance. <br />2015 Inspection Iff <br />0510015-INSP-2015 Page 18 of 37 <br />