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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
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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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Maintenance activities on three main stockpiles — The source uses a Division -approved method of <br />calculating dozer hours of operation based on historical hours per coal production (see August 2011 <br />O&M Plan Version 02). The highest daily hours of operation on the ROM stockpiles was 50 hours, <br />occurring on 10/5/2014. This value is below the 60 hours/day limit. <br />Maintenance activities on silo stockpiles — The source uses a Division -approved method of <br />calculating dozer hours of operation based on historical hours per coal production (see August 2011 <br />O&M Plan — Version 02). The highest daily `hours of operation' for the silo stockpiles was 9 hours, <br />occurring on 4/13/2014. This value is below the 40 hours/day limit. <br />Maintenance activities on refuse stockpiles — The source uses a Division -approved method of <br />calculating dozer hours of operation, based on historical hours per coal production (see August <br />2011 O&M Plan — Version 02). The highest daily `hours of operation' for the refuse stockpiles was <br />23 hours, occurring on 3/14/2013. This value is below the 75 hours/day limit. <br />It was verified for all `dozer hour limits' that the source is utilizing the calculation methodology <br />outlined in the approved O&M Plan. At the time of the 2012 inspection, the source explained that <br />this approved methodology provides a conservative estimate of actual dozer hours of operation. <br />Attachment A Limits: <br />-Point 014 and Point 016: There is a `truck hauling of coal' limit of 1,000,000 tpy (Point <br />014) from the storage stockpile and emergency stockpile. There is also a truck haulage limit of coal <br />from the ROM stockpile of 500,000 tpy (Point 016). During the inspection period, the source <br />trucked coal during Feb 2014 from the facility. This coal was trucked from silos, which are <br />included under the 1,000,000 tpy limit of Point 014. There was no truck hauling of coal from the <br />ROM stockpile during the inspection period. The source is in compliance with truck haulage limits <br />listed in Attachment A. <br />-Point 019: Throughput of ventilation air shall not exceed 3,000,000 cubic feet per minute. <br />Shaft #2 fans shall be restricted to one (1) fan operating at any time. The source confirmed during <br />the inspection that only one (1) Shaft #2 fan is operated at a time. Provided records also verified <br />that the source calculates throughput of ventilation air on a monthly and rolling 12 -month average, <br />with the highest monthly average of 1,537,730 acfm occurring during the month of Dec 2013, and <br />the highest rolling 12 -month average of 1,411,029 acfm occurring during the 12 -month period <br />ending Apr 2014. The source appears to typically operate with a rolling 12 -month average <br />ventilation air throughput around 1,350,000 acfm. These values are below the permitted limits for <br />this AIRS Pt. <br />The source is in compliance with all throughput and production limits listed in this condition. <br />Emissions of air pollutants shall not exceed the following limitations, and the specific limits in <br />Attachment A (as calculated in the Division's preliminary analysis): (Reference: Regulation 3, Part B, III. <br />A. 4) <br />Particulate Matter: 68.8 tons per year. <br />PM 10 (Particulate Matter<10 gm): 60.3 ton per year. <br />Particulate Matter - Fugitive: 85.4 tons per year. <br />PM 10 (Particulate Matter<10 µm) - Fugitive: 27.9 tons per year. <br />2015 Inspection A <br />0510015-INSP-2015 Page 12 of 37 <br />
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