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2017-11-01_GENERAL DOCUMENTS - C1980007
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2017-11-01_GENERAL DOCUMENTS - C1980007
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Last modified
11/30/2017 10:47:11 AM
Creation date
11/7/2017 7:34:31 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
General Documents
Doc Date
11/1/2017
Doc Name
Request for Informal Review
From
Wild Earth Guardians
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
JRS
LDS
Media Type
D
Archive
No
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Compliance with opacity standards shall be demonstrated according to <br />§ 60.11. <br />Source is in compliance with the requirements of Subpart Y, as well as most of the <br />General Provisions of Subpart A. No opacity above the applicable thresholds was <br />observed from any point during the inspection, and the source accurately records <br />all startups, shutdowns, and malfunctions as necessary. No concealment of <br />emissions has been observed. However, opacity was observed during the loading <br />of the rock dust silo, and there was significant buildup of rock dust around the <br />area of the baghouse associated with that unit. The rock dust ioader at the time of <br />the inspection did not appear to determine the psi loading rate of the silo based on <br />the silo/baghouse recommended parameters, but instead based it solely on the <br />capabilities of the truck. Similarly, the source did not report performing regular <br />maintenance on the silo baghouse. Following the inspection, it was established <br />that the opacity was the result of an incorrectly installed access door gasket, <br />which was replaced immediately following the inspection. <br />As opacity was observed at the time of the inspection and there appeared to be a <br />significant amount of buildup around the baghouse, it was determined that the <br />source was not operating in a manner consistent with good air pollution control <br />practices for minimizing emissions, and is thus NOT in compliance with paragraph <br />a. of this Condition. <br />10. Transfer points shall be enclosed to minimize emissions of particulate matter. <br />All transfer points and conveyors are enclosed as required. Source is in <br />compliance. <br />11. Public access shall be precluded, as per Mountain Coal Company's January 26, 2010 <br />letter to Mr. Jon Torizzo, in all areas within the modeling receptor exclusion zone as <br />submitted with the modeling with the application. Fenced areas shall be posted with no <br />trespassing signs. <br />The facility is fenced in with no trespassing signs posted to preclude public <br />access. Source is in compliance. <br />12. This source shall be limited to the maximum production rates and emissions controls as <br />listed in Attachment A. Daily records of the actual production rates shall be maintained by <br />the applicant and made available to the Division for inspection upon request. <br />As listed above under Conditions 6 and 7, the source has demonstrated <br />compliance with all production/throughput and emissions limits as listed in <br />Attachment A. Source is in compliance. <br />13. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at <br />any such time that this source becomes major solely by virtue of a relaxation in any <br />permit condition. Any relaxation that increases the potential to emit above the applicable <br />PSD threshold will require a full PSD review of the source as though construction had not <br />yet commenced on the source. The source shall not exceed the PSD threshold until a <br />PSD permit is granted. (Reference: Regulation No.3, Part D, Section VI.8.4.) <br />There have been no relaxations in permit requirements. However, as the source <br />may have significant emissions of VOCs which have yet to be more precisely <br />quantified, the source may be subject to PSD review following the coming <br />enforcement action and subsequent permit modifications. <br />2012 Air Pollution Inspection <br />0510015-INSP-2012.docx Page 20 of 30 <br />
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