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the system can continue to operate with a certain level of uncontrolled emissions, and thus the <br />baghouse is a control device on the system, not an intrinsic component that must be correctly <br />operational in order to load the silo. The source was requested to submit an APEN for this Point <br />on January 28, 2013. In a response received by the Division on February 14, 2013, MCC <br />reported total rock dust throughput in 2012 of 15,609 tons. At a requested throughput of 20,000 <br />tons per year, MCC calculated total uncontrolled PM emissions to be 31.4 tons, thus requiring a <br />permit for this activity. In the February 14th response, MCC indicated that they would overnight a <br />copy of the APEN and associated filing fee to the Division for this Point. The appropriate forms <br />were received February 15th, 2013. <br />-NSPS Subpart IIII Engines: MCC reported in their June 29, 2012 Title V application that due to <br />recent changes regarding APEN exemptions for engines, they are unsure as to whether certain <br />engines at their facility are subject to permitting. Following the inspection, the source submitted <br />information on applicable stationary engines at the facility which may be subject to NSPS Subpart <br />IIII. Due to the current 'catch-all' requirement in Regulation 3, Part B, Section II.D., all sources <br />subject to a Division -adopted NSPS (including NSPS Subpart IIII), regardless of size or fuel <br />consumption, are required to obtain a permit. Once informed of this requirement, MCC submitted <br />the following information concerning possible NSPS Subpart IIII engines: <br />-Generator for Main Office building Server: Diesel 50 hp engine, manufactured in 2009 <br />and installed in 2010. This engine is subject to NSPS Subpart IIII Tier 3 emissions <br />standards, and requires a Permit. The source was requested to submit an APEN for this <br />unit on January 28th, 2013, and the APEN was received on February 15, 2013. <br />-Start-up generator for main Emergency fan generator: Diesel 66.9 hp engine, <br />manufactured in September 2005 and installed in 2010. The manufacture date of this <br />engine is prior to the applicability dates of NSPS Subpart IIII. The unit was bought from a <br />dealer in Brighton, and MCC submitted confirmation on March 8, 2013 from the supplier <br />(see attached) that the unit was purchased new at that time. If operated outside of <br />Colorado and brought into the state during the applicability dates of NSPS Subpart !Ill. <br />the unit would be subject to the State -only 'new to Colorado relocation provisions'. These <br />provisions state that units brought into Colorado are considered 'New' as of the date of <br />relocation into the State (Ref: Regulation 6, Part B, Section I.B. and PS Memo 10-03). <br />As this unit was not operated outside of the State and relocated into Colorado during the <br />applicability dates of NSPS Subpart IIII, and the unit has fuel consumption and emissions <br />below applicable thresholds, this engine does not require an APEN submission or permit. <br />No additional action is required for this engine. <br />-Generator for Emergency escape hoist on Shaft #1: This diesel engine was purchased <br />and installed prior to 2000, and is thus not subject to NSPS Subpart IIII. Similarly, as this <br />small emergency generator is rarely used for testing and emergencies only, emissions <br />from the unit are below APEN/Permitting thresholds. No additional action is required for <br />this engine. <br />-Generator for 'New' Emergency Escape Hoist: This engine is propane -fired, and thus <br />not subject to NSPS Subpart IIII. Similar to the Shaft #1 hoist, the unit is rarely used for <br />testing and emergencies only, and emissions from this unit are below APEN/Permitting <br />thresholds. No additional action is required for this engine. <br />The recent APEN exemption changes referenced in the Title V application were not associated <br />with the NSPS catch-all requirement in Regulation 3. Although the requirement for permitting <br />small stationary engines is not intuitive, according to permit engineer notes listed in the Division's <br />Permit Tracking System, the issues regarding genset permit applicability were discussed with the <br />source on November 30, 2010, and they indicated that APENs would be submitted (See Picture <br />#5). Based on the information provided following this inspection, the source appears to have one <br />(1) engine located on-site which was previously unreported, but requires a permit. Once informed <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 6 of 30 <br />