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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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Emissions of air pollutants, from the combined operation of both engines, shall not exceed the following <br />limitations (as calculated in the Division's preliminary analysis): (Reference: Regulation No. 3, Part B, <br />Section II.A.4.) <br />Nitrogen Oxides: 12.36 tons per year. <br />Carbon Monoxide: 15.23 tons per year. <br />This AIRS Pt description includes only one engine (rated at 3,251 bhp). However, to prevent the <br />large engine from stalling, the source operates a smaller generator/engine which powers the large <br />engine's fan during startup. The small secondary engine (rated at only 67 hp) is not used following <br />startup, and when evaluated independently, operates below APEN-reporting thresholds. The <br />smaller engine would have a relatively insignificant contribution to emissions from this point. This <br />condition does not require the facility to track emissions. As total fuel consumption and hours of <br />operation are below the permitted limits listed in Condition 8, and the unit appears to be <br />maintained according to the recommendations of the manufacturer, the source is presumed to be <br />operating in compliance with the emissions limits listed in this condition. <br />Note: The source submitted a cancellation notice on 10/26/2015 to remove the small engine from <br />this permit, as it is no longer required to be reported following the removal of the "NSPS Catchall" <br />requirements from AQCC Regulations in 2014. <br />7. Within one hundred and eighty days (180) after commencement of operation, the applicant shall submit to <br />the Division for approval an operating and maintenance plan for all control equipment and control <br />practices, and a proposed record keeping format that will outline how the applicant will maintain <br />compliance on an ongoing basis with the requirements of condition no 6 listed above. The operating and <br />maintenance plan shall commence at startup. (Reference: Regulation No. 3, Part B, Section III.G.7. <br />The source submitted an operating and maintenance plan for the engine along with all other self <br />certification documents in August of 2010. The O&M Plan was not appropriately routed to the <br />O&M Plan coordinator for approval at that time, but was later reviewed and approved on <br />February 6, 2013. The source follows all inspection and maintenance procedures as required by the <br />manufacturer. Similarly, the source performs a visible emissions observation during monthly <br />readiness testing and has not observed visible emissions during normal operation (i.e. following <br />initial startup). The source is in compliance with this condition. <br />These sources shall be limited to a maximum fuel use rate, and maximum hours of operation, as listed <br />below and all other activities, operational rates and numbers of equipment as stated in the application. <br />Annual records of the actual consumption rate shall be maintained by the applicant and made available to <br />the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4.) <br />Consumption of #2, Low Sulfur Diesel fuel shall not exceed 75,000 gallons/year. <br />Hours of operation shall not exceed 500 hours per year. <br />The unit is rarely used, operated during 1 hour monthly tests and during emergencies only. The <br />source tracks monthly hours of operation (using the onboard hour meter) and combines this <br />information into a rolling 12 -month total. During the entire compliance period, the unit did not <br />have any months with greater than 2 operating hours per month, or greater than 17 operating <br />hours during any rolling 12 -month period. The source tracks diesel deliveries to the tank only, <br />rather than consumption by the unit during any given year. Prior to this inspection, the facility only <br />had 1,600 gallons of diesel fuel delivered to the facility since 2010 (startup of the unit). During this <br />2015 Inspection A�k' <br />0510015-INSP-2015 Page 20 of 37 <br />
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