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A change in actual emissions, above the level reported on the last APEN submitted, of 50 pounds <br />of lead <br />For any non -criteria reportable pollutant: <br />If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level <br />reported on the last APEN submitted to the Division. <br />b. Whenever there is a change in the owner or operator of any facility, process, or activity; or <br />Whenever new control equipment is installed, or whenever a different type of control equipment <br />replaces an existing type of control equipment; or <br />d. Whenever a permit limitation must be modified; or <br />Below is a list of the source's most recent APEN submittals for each AIRS Pt covered by this <br />permit: <br />AIRS Pt <br />ID <br />Description <br />Previous APEN <br />Revised APEN <br />Due* <br />Most Recent <br />APEN Received <br />Received <br />011 <br />Conveyors and Transfer Points <br />11/24/2009 <br />10/25/2014 <br />11/13/2014 <br />012 <br />Coal Processing Plant — <br />Crushers/Screens <br />11/24/2009 <br />10/25/2014 <br />11/13/2014 <br />013 <br />Coal Silos and Train Loadout System <br />11/24/2009 <br />10/25/2014 <br />11/13/2014 <br />014 <br />Coal Stockpiles <br />11/24/2009 <br />10/25/2014 <br />11/13/2014 <br />015 <br />Refuse Stockpiles <br />11/10/2009 <br />10/11/2014 <br />11/13/2014 <br />016 <br />Truck Hauling of Coal <br />11/24/2009 <br />10/25/2014 <br />11/13/2014 <br />019 <br />Mine Ventilation Shafts <br />11/24/2009 <br />10/25/2014 <br />11/13/2014 <br />020 <br />Coal Prep Plant (washplant) <br />11/10/2009 <br />10/11/2014 <br />11/13/2014 <br />*Revised APEN Due date is calculated as 30 days prior to the previous APEN's expiration at the end of the 5 -year term. <br />Since the 2014 APEN submission, there have been no process modifications or changes in emissions <br />which would require a more recent submittal for the listed Pts above (with the exception of AIRS Pt <br />019). As listed in the table above, the source's previous APENs were submitted in November 2009, <br />with a five year expiration occurring in November 2014. As required by AQCC Regulation 3, Part <br />A, Section II.C.3.a, revised APENs are due at least 30 days prior to the expiration of the 5 -year <br />term. Because the 2014 APEN updates were received only eleven days prior to expiration for Pts <br />011-019, and three days after expiration of Pt 020, the source is in violation of the APEN-reporting <br />requirements of Regulation 3, as referenced in this condition. Because the source submitted revised <br />APENs within days of the required time period, enforcement discretion is recommended regarding <br />this violation. <br />However as explained in the `VOC Emissions Discussion' on page 4 of this report, MCC has VOC <br />emissions above APEN-reporting thresholds from multiple ventilation points at the mine, including <br />those covered by AIRS Pt 019. VOC emissions associated with ventilation air have not been <br />reported to the Division on any APENs. <br />Therefore, as the source has been aware of the VOC emissions issue at the mine since 2012, and has <br />not submitted an APEN requesting modification to their facility -wide permit to include VOC <br />2015 Inspection A17 <br />0510015-INSP-2015 Page 15 of 37 <br />