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shall be included in the demonstration of compliance with the yearly non - <br />fugitive emission limits listed above. <br />Compliance with the fugitive emission limits shall be demonstrated by not <br />exceeding the production limits in condition number 6 and by following <br />the attached fugitive dust emissions control plan. <br />The source provided emissions records (see attached) to demonstrate compliance <br />with Attachment A emissions limits: <br />-Point 011: Conveyors and transfer points are limited to 6.2 tpy and 4.2 tpy of PM <br />and PM10 respectively. The highest 12 -month rolling total of emissions from this <br />Point was 4.99 tpy and 3.32 tpy for PM and PM10 respectively, which occurred <br />during the period of Sept 2011 -Aug 2012. These values are below the permitted <br />limits for this point. <br />-Point 012: Coal Processing System emissions are limited to 5.4 tpy and 1.6 tpy for <br />PM and PM10 respectively. The highest 12 -month rolling total of emissions from <br />this Point was 3.66 tpy and 1.13 tpy for PM and PM10 respectively, which occurred <br />during the period of Aug 2010 -July 2011. Similarly, the source is limited to daily <br />PM and PM10 emissions from this Point of 51.0 lbs/day and 15.4 lbs/day <br />respectively. The highest daily emission rate occurred on 8/16/2012 with 44.5 <br />lbs/day and 13.7 lbs/day of PM and PM10 emissions respectively. These values are <br />below the permitted limits for this point. It was noted that during the period <br />reviewed, there were two days in the records which are listed to have negative <br />emissions (10/19/2011 and 5/30/2012). The source responded to an inquiry into <br />this irregularity by stating that "the negative values ... were a result of inventory <br />adjustments made after on-site stockpile volume surveys were conducted. The <br />actual stockpiled volumes were found to be less, so the reported coal processing <br />number was adjusted on those days to more accurately reflect the actual total coal <br />inventory." This action/explanation is acceptable to the Division, in that it is a <br />reasonable recordkeeping quality assurance procedure. <br />-Point 013: Coal storage silos and loadout systems are limited to 0.12 tpy and 0.06 <br />tpy for PM and PM10 respectively. The highest 12 -month rolling total of emissions <br />from this Point was 0.09 tpy and 0.05 tpy of PM and PM10 respectively during <br />several 12 -month periods. The source is also limited to 5.3 tpy and 1.6 tpy fugitive <br />PM and PM10 emissions. The highest 12 -month rolling total of emissions from this <br />Point was 3.84 tpy and 1.28 tpy from Nov 2010 -Oct 2011. These values are below <br />permitted limits for this point. <br />-Point 014: Emissions from coal stockpiles and associated hauling of coal are <br />limited by the source following the fugitive dust control plan. Fugitive PM and <br />PM10 limits are 10.7 tpy and 7.9 tpy respectively. As the source has demonstrated <br />compliance with the control plan and has not exceeded their production limits, and <br />without credible evidence to suggest the contrary, they have demonstrated <br />compliance with these limits. <br />-Point 015: Emissions from coal refuse piles and associated mobile equipment and <br />hauling of coal are limited by the source following the fugitive dust control plan. <br />Fugitive PM and PM10 limits are 38.4 tpy and 11.4 tpy respectively. As the source <br />has demonstrated compliance with the control plan, dozer hours of operation, and <br />have not exceeded production/material handling limits, they have demonstrated <br />compliance with these limits. <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 16 of 30 <br />