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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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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 />
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