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38.4 tpy and 11.4 tpy respectively. As the source has demonstrated compliance with the control <br />plan, dozer hours of operation, and has not exceeded production/material handling limits, they <br />have demonstrated compliance with these fugitive emissions limits. <br />-Point 016: Emissions from hauling of coal from the ROM storage pile are limited by the source <br />following the fugitive dust control plan, and not exceeding the truck haulage limit of 500,000 tpy. <br />The source is limited to PM and PM10 emissions from these activities of 9.2 tpy and 2.5 tpy <br />respectively. The source ceased most of these truck hauling activities in Sept 2010, with the only <br />hauling occurring during this compliance period in Feb 2014 with 693 tons of material hauled from <br />silos. This corresponded to PM and PM10 emissions of 0.00 tons from this limited activity, below <br />permitted limits for this point. <br />-Point 019: Coal mine ventilation shaft emissions are limited to 49.2 tpy for both PM and PM10 (all <br />PM exiting the mine shafts is conservatively estimated to be PM10). The source has operated with <br />ventilation air throughput below the permit limit of 3,000,000 cubic feet per minute, and reported <br />actual emissions to be a maximum of 23.13 tpy during the 12 -month rolling average period ending <br />Apr 2014. All values are below permitted limits for this point. <br />-Point 020: Coal prep plant process equipment emissions are limited by all processes being <br />enclosed, and by a 4,500,000 tpy processing rate limit. Associated emissions from this activity are <br />limited to 3.3 tpy and 1.7 tpy for PM and PM10 respectively. The highest reported emissions from <br />the Coal prep plant were 1.62 tpy and 0.76 tpy for PM and PM10 respectively, which occurred <br />during the 12 -month rolling total period ending Sept 2012. These values are below the permitted <br />limits for this point. <br />The source also provided coal moisture values, as recorded monthly and on a rolling 12 -month <br />total. For any given month during the reporting period, coal moisture remained above 7%, and did <br />not drop below 10.4% for any given month. This coal moisture limit was included in the source's <br />previous material handling permit (95GU508-1), and is part of the fugitive dust control plan, but <br />has not been incorporated into the current facility -wide permit 09GU1382. However, as <br />Attachment A lists that one of the main emissions controls applied throughout the process is the <br />natural moisture content of the coal, the fact that the moisture content has remained above 10.4% <br />demonstrates that the source is in compliance with this control requirement. Similarly, Attachment <br />A requires the source to follow the approved dust control plan, which includes the >7% moisture <br />content requirement (see attached). <br />Along with verifying compliance with emission limits, the inspector verified that all calculations <br />were being performed on a rolling 12 -month total as required, and using the emissions factors listed <br />in Attachment A. Therefore, as listed individually above, the source is in compliance with all <br />emissions limits in this condition. <br />8. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, <br />Section II.C.) <br />a. Annually whenever a significant increase in emissions occurs as follows: <br />For any criteria pollutant: <br />For sources emitting less than 100 tons per year, a change in actual emissions of five tons per <br />year or more, above the level reported on the last APEN submitted; or <br />2015 Inspection I& <br />0510015-INSP-2015 Page 14 of 37 <br />