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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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Compliance with the yearly emission limits shall be determined on a rolling twelve (12) month <br />total. <br />Notes: For AIRS IDs 051/0015/011, 012, 013, 019 & 020, Coal Processing System: The permit <br />holder shall calculate emissions as defined in Attachment A, based on daily production <br />and keep a compliance record on site in order to demonstrate compliance with the above <br />emission limitations. Annual emissions shall be calculated based on the previous twelve <br />(12) months' emission data. These calculated annual emissions shall be included in the <br />demonstration of compliance with the yearly non -fugitive emission limits listed above. <br />Compliance with the fugitive emission limits shall be demonstrated by not exceeding the <br />production limits in condition number 6 and by following the attached fugitive dust <br />emissions control plan. <br />MCC tracks all required daily, monthly, and rolling 12 -month emissions as required. The source <br />provided emissions records to demonstrate compliance with Attachment A emissions limits (see <br />attached): <br />-Point 011: Conveyors and transfer points are limited to 6.2 tpy and 4.2 tpy of PM and PM10 <br />respectively. The highest 12 -month rolling total of emissions from this Point was 5.41 tpy and 3.61 <br />tpy for PM and PM10 respectively, which occurred during the 12 -month period ending Nov 2012. <br />These values are below the permitted limits for this point. <br />-Point 012: Coal Processing System emissions are limited to 5.4 tpy and 1.6 tpy for PM and PM10 <br />respectively. The highest 12 -month rolling total of emissions from this Point was 3.83 tpy and 1.18 <br />tpy for PM and PM10 respectively, which occurred during the period of Aug 2013 -July 2014. <br />Similarly, the source is limited to daily PM and PM10 emissions from this Point of 51.0 lbs/day and <br />15.4 lbs/day respectively. The highest daily emission rate occurred on 4/13/2014 with 44.00 lbs/day <br />and 13.54 lbs/day of PM and PM10 emissions respectively. These values are below the permitted <br />limits for this point. It was noted that during the period reviewed, there were a few days in the <br />records which are listed to have negative emissions. The negative values are a result of inventory <br />adjustments made after on-site stockpile volume surveys are conducted. The actual stockpiled <br />volumes were found to be less than presumed, so the reported coal processing number was adjusted <br />on those days to more accurately reflect the actual total coal inventory. This action is acceptable to <br />the Division, in that it is a reasonable recordkeeping quality assurance procedure. <br />-Point 013: Coal storage silos and loadout systems are limited to 0.12 tpy and 0.06 tpy for PM and <br />PM10 respectively. The highest 12 -month rolling total of emissions from this Point was 0.10 tpy and <br />0.05 tpy of PM and PM10 respectively during several 12 -month periods. The source is also limited <br />to 5.3 tpy and 1.6 tpy fugitive PM and PM10 emissions. The highest 12 -month rolling total of <br />fugitive emissions from this Point was 4.15 tpy and 1.38 tpy from Jan 2012 -Dec 2012. These values <br />are below permitted limits for this point. <br />-Point 014: Emissions from coal stockpiles and associated hauling of coal are limited by the source <br />following the fugitive dust control plan. Fugitive PM and PM10 limits are 10.7 tpy and 7.9 tpy <br />respectively. As the source has demonstrated compliance with the control plan and has not <br />exceeded their production limits, and without credible evidence to suggest the contrary, the source <br />has demonstrated compliance with these fugitive emissions limits. <br />-Point 015: Emissions from coal refuse piles and associated mobile equipment and hauling of coal <br />are limited by the source following the fugitive dust control plan. Fugitive PM and PM10 limits are <br />2015 Inspection &,W <br />0510015-INSP-2015 Page 13 of 37 <br />
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