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VERMONT AGENCY OF NATURAL RESOURCESDepartment of Environmental ConservationAir Quality & Climate DivisionTECHNICAL ANALYSIS OF AN AIR CONTAMINANT SOURCEFOR A PERMIT TO CONSTRUCT AND OPERATE#AOP-16-008 / DEC #BR95-0106#AOP-12-024 / DEC #BR95-0106May 19, 2017Prepared By: Tony Mathis, Environmental EngineerSOURCE / FACILITY:Moretown Municipal Solid Waste Facility (Facility) consisting of the Moretown Landfill (Landfill Operation) and Moretown Landfill Gas to Energy Operation (LFGTE Operation)187 Palisades ParkWashington CountyWaterbury, VT 05676LANDFILL OPERATIONOWNER/OPERATOR:Moretown Landfill, Inc. (MLI)90 Fort Wade Rd.Ponte Verde FL 32081CONTACT:Mr. John Schwalbe.Moretown Landfill, Inc.19 Kaiser DriveWaterbury, VT 05676-8920Tel: (802) – 802-236-3832LFGTE OPERATIONOWNER/OPERATOR:EPP Renewable Energy, LLC (EPP) 1605 North Cedar Crest Boulevard, Suite 509 Allentown, PA 18104 CONTACT:Mr. Steve GabrielleEPP Renewable Energy, LLC (EPP) 1605 North Cedar Crest Boulevard, Suite 509 Allentown, PA 18104 Tel: (610) - 557-1873AREA DESIGNATION:Attainment for PM10, SO2, NO2, CO, & Pb / Unclassified for ozoneUTM COORDINATES:682746 m E, 4909105 m N, Zone 18 This Technical Support Document by the Agency of Natural Resources, Department of Environmental Conservation, Air Quality & Climate Division (hereinafter “Agency”) is intended to provide additional technical information, discussion and clarification in support of the Permit. It is not intended to provide a comprehensive review of the Facility or the permit process or to duplicate the information contained in the Permit or elsewhere. 1.0INTRODUCTIONMoretown Landfill, Inc. (also referred to herein as "MLI”) owns and operates a municipal solid waste (MSW) landfill (Landfill Operation) on Palisades Park in the town of Moretown, Vermont. EPP Renewable Energy, LLC (also referred to herein “EPP”) owns and operates a landfill gas to energy facility (LFGTE Operation) that is located on property leased from MLI at the unlined area of the Landfill Operation. The LFGTE Operation combusts landfill gas (LFG) from the Landfill Operation in an internal combustion engine, and uses this LFG-fired engine to power an electrical generator, generating electrical power for sale on the regional electric grid The Facility consists of the Landfill Operation and the LFGTE Operation. The Landfill Operation is comprised of the original Unlined Landfill that operated from approximately 1972 until 1994 when it was closed and capped. In 1995 a new, lined landfill began operations near the Unlined Landfill. This new, lined landfill consists of Cells 1, 2 and 3. Cells 1 and 2 were closed and capped after reaching design capacity, and Cell 3 ceased accepting waste on July 15, 2013. Cell 3 had its final impermeable cap installed after the Landfill Operation was closed to waste acceptance on July 15, 2013, but refuse contained within the various cells of the landfill will continue to generate LFG for several years after the landfill was closed to waste acceptance. The LFGTE Operation was constructed in 2008, with the installation of two (2) CAT G3520C LE LFG fired internal combustion engines (CAT G3520C engine) that begin operating in December 2008. EPP has indicated that due to declining LFG volumes from the Landfill Operation that they will be decommissioning one (1) of the CAT 3520C engines at the LFGTE Operation. Accordingly, this permit renewal will only permit the operation of the one (1) remaining CAT 3520C engine. With the decrease in emissions resulting from the decommissioning of one (1) CAT G3520C engine, the emissions from the Facility will have fallen below the 100 ton per year per criteria pollutant threshold for Title V applicability. The Facility will no longer be subject to the Title V operating permit requirements, and will become subject to state-only operating permits. MLI is required in previous Air Pollution Control Permits, and as part of the solid waste certification for the Landfill Operation, to actively collect LFG generated by waste decomposition at the Landfill Operation and route the LFG to a combustion device to thoroughly destroy the non-methane organic compounds (NMOCs) contained in the LFG. The LFG collection system consists of a series of LFG collection points including vertical wells drilled into refuse-containing areas of the Landfill Operation as well as horizontal collection trenches and leachate cleanout piping, all connected by piping to a vacuum blower that maintains a negative pressure in the lines to extract LFG from the Landfill Operation. Collected LFG is either combusted in a flare owned and operated by MLI, or sold to EPP. EPP treats the LFG with a dewatering, chilling, and filtration treatment system to remove impurities in the LFG before using the treated LFG as gaseous fuel in the CAT G3520C engine at the LFGTE Operation. The CAT G3520C engine at the LFGTE Operation is rated to generate a maximum of 1.6 megawatts (MW) of electrical power. MLI has closed the Landfill Operation to acceptance of waste as of July 15, 2013, but continues to maintain and operate the LFG collection system, flare(s), and perform inspections and maintenance of the landfill cap. Refuse contained within the landfill is anticipated to generate LFG for several years, although the rate at which LFG is generated within the landfill will likely decrease over time, as decomposable material within the landfill is consumed by anaerobic bacteria. For purposes of estimating air emissions from the Facility, it is assumed that emissions from the Landfill Operation will consist of the generation of 1,256 standard cubic feet per minute (scfm) of LFG, and the capture of 1,130 scfm of LFG. This review of the Facility and its associated air emissions includes the following: #AOP-12-024: Permit to Operate and an update to the Permit to Construct for the Landfill Operation, to include post-construction updates to the generation of 1,256 scfm of LFG, the capture of 1,130 scfm of LFG, the installation of final capping for the Landfill Operation, the continued operation of an LFG collection and control system, and updates regarding LFG flare(s) installed at the Landfill Operation. #AOP-16-008: Renewal of the Permit to Operate for one (1) CAT G3520C LFG-fired internal combustion engine generators at the LFGTE Operation. Administrative MilestonesTable 1-1: Administrative SummaryAdministrative ItemResult or DateDate Application(s) Received (#AOP-12-024 / #AOP-16-008):06/29/2012 / 07/01/2016Date Application(s) Administratively Complete: (#AOP-12-024 / #AOP-16-008):06/29/2012 / 07/06/2016Date Application(s) Technically Complete: (#AOP-12-024 / #AOP-16-008):04/27/2017 / 01/24/2017Date Proposed Decision: 04/28/2017Date Final Decision: 05/19/2017Date & Location Draft Decision/Comment Period Noticed:Environmental Notice Bulletin04/28/2017Date & Location Public Meeting Noticed:Not RequestedDate & Location of Public Meeting:Not RequestedDeadline for Public Comments:05/08/2017Classification of Source Under §5-401:§5-401 (6)(c) [Stationary reciprocating internal combustion engines…having a rating of 450 brake horsepower output or greater] §5-401(16) (Any source …which would otherwise be subject to regulation pursuant to the Clean Air Act, as amended (42 USC 7401, et seq.)§5-401(17 [Such other sources as may be designated as air contaminant sources by the Air Pollution Control Officer on a case-by-case basis]Classification of Application: (#AOP-12-024 / #AOP-16-008):Major Modification / RenewalConstruction and Operating Permit: Designation of Facilities:Subchapter XFacility SIC/NAIC Code(s): (#AOP-12-024 / #AOP-16-008): 4953 / 562212 and 4931 / 221129Facility SIC/NAIC Code Description(s):Refuse Systems, Solid Waste Landfills and Electric and other Services Combined, Other Electric Power GenerationTable 1-2: Future Allowable Facility Air Contaminant Emissions (tons/year)1PM/PM10/PM2.5 SO2NOxCOVOCsHAPs 3CO2e 35.717.613.879<25<10/2551,6771PM/PM10/PM2.5 – total particulate matter, total particulate matter of 10 micrometers in size or smaller and total particulate matter of 2.5 micrometers in size or smaller, respectively (unless otherwise specified, all PM is assumed to be PM2.5); SO2 - sulfur dioxide; NOx - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.2For purposes of designation the Facility as a major or minor source of federal hazardous air pollutants (HAPs), the emissions of individual HAPs from the Facility are each <10 tpy and emissions of total HAPs combined are <25 tpy. Actual total combined HAPs from the Facility are estimated at <10 tpy3CO2e - Carbon dioxide equivalent emissions. Includes where appropriate carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and other fluorinated greenhouse gases. Emissions are from both biogenic and non-biogenic sources. See Section 3.3 for further details.2.0FACILITY DESCRIPTION2.1 Facility Locations and Surrounding AreaThe Facility is located approximately 3 miles southeast of downtown Waterbury. The area surrounding the Facility is primarily wooded areas and cultivated fields, with some houses and a composting operation located to the northwest of the Facility. The Facility is bounded to the north and east by Vermont Route 2, the Winooski River and US Interstate Highway 89. Forested areas bound the south side of the Facility, and a mix of forested areas and structures bound the west side of the Facility. The Facility is located approximately 126 km from the Lye Brook Wilderness area in Manchester, Vermont and approximately 82 km from the Great Gulf and Dry River Wilderness areas in New Hampshire. 2.2 Facility DescriptionThe Facility consists of two different activities, the Landfill Operation and the LFGTE Operation, which are operated by different parties. Allowable emissions from the Facility are the aggregate of emissions from the Landfill Operation and the LFGTE Operation. The Landfill Operation is classified by the Standard Industrial Classification (“SIC”) as 4953(Refuse Systems, Solid Waste Landfills) and by the North American Industrial Classification System (NAICS) as 562212 (Solid Waste Landfills). The LFGTE Operation is classified as SIC 4931 (Electric and Other Services Combined, Other Electric Power Generation) and 221129 (Other Electric Power Generation).The Landfill Operation and the LFGTE Operation are considered to be a single source of air emissions, and are collectively referred to herein as "Facility". Allowable emissions from the Facility are the aggregate of emissions from the Landfill Operation and the LFGTE Operation. Only a portion of the Facility was previously permitted, with the permit for the LFGTE Operation being issued to EPP. The Landfill Operation was not permitted, as this activity did not meet the requirements for a Title V permit, and air emissions from the Landfill Operation had been addressed under the Landfill Operations Solid Waste Permit. However, to better delineate responsibility between the two operations and to provide a clear understanding of the regulatory status of the activities at the Facility, the Agency is issuing two separate permits for this single Facility, MLI is responsible under #AOP-12-024 for the Landfill Operation, which consists of the closed and capped original unlined landfill, and subsequent lined landfill cells, and the currently operating LFG collection system and flares operated by MLI that are used to combust LFG without energy recovery. LFG from the area of the closed and capped unlined landfill that operated from approximately 1972 until 1994 when it was closed and capped. The LFG control system at the Unlined Landfill originally consisted of a passive flare system that was upgraded to an active gas collection system no later than October 31, 1996. In 1995 a new, lined landfill began operation near the original landfill. This lined landfill consists of Cells 1, 2, and 3. Cell 1 was closed and capped in approximately 1999, Cell 2 was closed and capped in approximately 2007, and Cell 3 ceased accepting waste on July 15, 2013, after which it was closed and capped. MLI is currently required to actively collect the LFG that is generated from the decomposition of refuse within the lined landfill areas and route the LFG to a combustion device to thoroughly destroy NMOCs contained in the LFG. The LFG collection system consists of a series of gas collection points including wells drilled into the landfill as well as horizontal collection trenches and leachate cleanout piping, all connected by piping to a blower that maintains a negative pressure in the lines to extract LFG from the landfill. A demister knock-out vessel is installed to remove moisture droplets from the gas is installed in the collection lines before these lines enter the blower. The collected LFG is sold to EPP, who treats the LFG to remove impurities before using the treated LFG as a gaseous fuel in the internal combustion engine at the LFGTE Operation. Any LFG collected by the Landfill Operation that is not combusted in the engine at the LFGTE Operation, such as LFG generation excess to the needs of the engine or gas generated during periods when the engine is off-line is routed to an on-site flare operated by MLI as part of the Landfill Operation to ensure continued complete combustion of the LFG. The LFGTE Operation currently consists of one (1) LFG-fired CAT 3520C internal combustion engine nominally rated at 2,233 bhp and 1,600 kW of generation capacity. The LFGTE Operation also includes a gas skid that pressurizes and dries the LFG to improve gas quality and extend the service life of the engine. The blower on the gas skid applies a constant vacuum to the LFG collection system. The LFG initially enters the moisture separator on the gas skid, and experiences a sharp decrease in flow velocity due to an increased cross-sectional area, resulting in decreased dynamic pressure and promoting condensation. Entrained liquid droplets are removed by a mist eliminator within the moisture separator. From the moisture separator, the LPG enters the blower, moving from vacuum inlet to the positive pressure side of the blower. The compressed LFG then passes through a regulating valve and enters a coalescing filter to remove additional condensate formed as a result of the increased LFG pressure and decreased temperature. The LFGTE Operation has no emergency generator and no black-start capability. Equipment and operations at the Facility are summarized in the following table.Landfill Operation - SpecificationsLandfill Area/PhaseYears of Active Operation1Refuse Capacity (Mg) 2 / Landfill Size (acres)Cumulative Facility Refuse Capacity (Mg) 2 / Landfill size (acres) Unlined Landfill 1980 - 1994296,639 / (5 acres)296,639 / (5 acres)Landfill Cells 1, 2, and 31995- July 15, 20131,958,288 / (29 acres)2,254,927 / (34 acres)Landfill Operation - LFG Combustion DevicesLFG Combustion DeviceSize/ Rating 3Rating 4Location, stack heightOne (1) LFG Specialties skid-mounted Utility Ground Flare, serial number 198612” dia. /75 MMBtu/hr2,500 scfmLined Landfill; 35’ minimum.Landfill Operation - Miscellaneous EquipmentEquipmentRating 3LocationThree (3) LPG- fired Portable Space Heaters1 x 15,000 Btu/hr each1 x 24,000 Btu/hr each1 x 67,500 Btu/hr eachControl RoomOffice BuildingScale HouseOne (1) diesel fuel tank500 gallonsLFGTE CompoundOne (1) portable diesel engine powered generator200 bhp / 150kW LFGTE CompoundOne (1) portable gasoline engine powered generator10 bhp / 6 kWStorage TrailerThree (3) Leachate storage tanks1 x 330,000 gallon each2 x 15,000 gallon each3 x 30,000 gallon eachVariousLFGTE Operation - EquipmentEquipmentRating 3LocationOne (1) CAT G3520C Engine Engine Installed September, 20082,233 bhp (1,600 kW) each engine550 scfm LFG fuel flow each engineLFGTE Operation;20’ stack heightOne (1) Used Oil Tank1,000 gallonsLFGTE OperationOne (1) Lube Oil Storage Tank1,000 gallonsLFGTE OperationLFG pretreatment system: IES LFG scrubbing system including a gas blower unit, a demister / moisture knock-out vessel and a coalescing filter. 1,100 scfmLFGTE Operation1 Years of operation are approximate. The Landfill Operation ceased accepting waste on July 15, 2013. 2 Mg – Mega grams. To convert to English tons, multiply the Mg value by 1.1025. 3 MMBtu/hr – Million British thermal units per hour heat input, Btu/hr – British thermal units per hour heat input, bhp – brake horsepower rated output as specified by the manufacturer. kW - kilowatt electrical output. 4 scfm - standard cubic feet per minute of LFG. LFG is assumed to contain 40% - 60% methane with the balance predominately carbon dioxide but also includes ~1,190 ppm nonmethane organic compounds (NMOCs) based on application information provided by the Permittee for the Landfill Operation. The LFG flows are declining at the Landfill Operation, and the maximum LFG generation rate is anticipated to be approximately 660,000,000 scf per year based on registration data from 2015. LFG capture efficiency is assumed to be 90% over the remaining life of the closed and capped Landfill Operation based on registration data from 2015. 3.0QUANTIFICATION OF POLLUTANTSThe quantification of emissions from a stationary source is necessary in order to establish the appropriate regulatory review process for the operating permit application and to determine applicability with various air pollution control requirements. These determinations are normally based upon allowable emissions. Allowable emissions are defined as the emission rate calculated using the maximum rated capacity of the source and, if applicable, either: (a) the applicable emission standard contained in the Regulations, if any, or (b) the emission rate or design, operational or equipment standard specified in any order or agreement issued under the Regulations that is state and federally enforceable. An applicant may impose in its application an emission rate or design, or an operational or equipment limitation which may be incorporated in the Permit to restrict operation to a lower level. Examples of such limitations may include, but are not limited to, fuel restrictions or production limitsActivities at the Facility with emissions that are not insignificant or exempt include the following: Fugitive emissions from the Landfill Operation that are not captured by the LFG collection system. These emissions consist of NMOCs and hydrogen sulfide that are present in the LFG. Emissions of combustion byproducts from destruction of LFG in the Landfill Operation utility flare(s). The utility flare at the Landfill Operation is currently used to combust that portion of LFG generated by the Landfill Operation that is not combusted in the CAT 3520C engine at the LFGTE Operation, or as a backup combustion device for all collected LFG during periods when the CAT 3520C engine is off-line. Emissions of combustion byproducts from destruction of LFG in the one (1) CAT G3520C engine at the LFGTE Operation. Combustion byproducts include both criteria pollutants and VOCs formed by incomplete combustion. Emissions of uncombusted NMOCs from the flares and engine at the Facility. These combustion devices are not 100 percent effective in controlling NMOCs, and it is assumed that approximately 2 percent of the NMCOCs that pass through these devices are emitted to the ambient air. Emissions were estimated on a Facility basis. The individual Permittees at this Facility will each be responsible for estimating their components of overall Facility emissions. The estimation of potential to emit and allowable emissions of particulate matter (PM/PM10/PM2.5), sulfur dioxide (SO2), oxides of nitrogen (NOx), carbon monoxide (CO), volatile organic compounds (VOCs), hazardous air pollutants (HAPs) and hazardous air contaminants (HACs) from these sources are described below.3.1LFG Emissions: The total amount of LFG generated by the Landfill Operation was estimated by the Agency based on actual flow measurements of collected LFG. The Landfill Operation ceased accepting waste in 2013 and was capped with an impervious liner, and one of the CAT 3520C engines at the LFGTE Operation is to be decommissioned in early 2017 because of declining LFG flows. Based on this evidence of declining LFG generation, the Agency has determined that this is a reasonable means of estimating future LFG flows for these permits. The maximum annual LFG generation from the Landfill Operation was estimated at 660,000,000 standard cubic feet (scf) of LFG per year, based on 2015 registration data. The landfill cover and LFG collection system is estimated to collect approximately 90 percent of the LFG generated within the closed and capped Landfill Operation. Based on this annual generation over 8,760 hours per year, the annual LFG generation rate for the landfill is estimated at 1,258 standard cubic feet per minute (scfm). With a 90 percent control efficiency, approximately 1,130 scfm of LFG would be captured, and approximately 126 scfm of LFG would be emitted to the ambient air as fugitive emissions. LFG contains NMOCs, and the individual compounds comprising NMOCs may also be classified as volatile organic compounds (VOCs) and/or hazardous air pollutants (HAPs) and/or hazardous air contaminants (HACs). The Application for AOP-12-024 estimated the overall concentration of NMOCs in LFG as 1,190 parts per million by volume (ppmv) as hexane based on AP-42 Table 2.4-2 plus a 100% factor of safety. This value was used for subsequent estimates involving NMOCs. Sampling and analysis of LFG for NMOCs was performed in October 2010, and January 2012 to quantify certain individual NMOCs/VOCs. One compound that required additional evaluation is hydrogen sulfide (H2S). The concentration of H2S in LFG at the Facility has varied over the last several years, as concentrations of H2S are affected by the types of refuse that are placed in the landfill, and the amount of time this material has been landfilled. The largest amount of H2S generation in a landfill typically occurs in a three- to four-year period after the placement of sulfur-containing refuse, such as gypsum wallboard or sewage sludges. As the landfill has been closed to waste acceptance since July 2013, it is likely that H2S concentrations are decreasing, and will continue to decrease in the future. For the purposes of estimating H2S concentrations in LFG for this permit, the Agency assumed that future H2S concentrations would not exceed those reported in the 2016 registration data, which ranged between 350 to 110 ppmv, with an average of 206 ppmv. To provide for a conservative estimate, it was assumed that H2S will be present in LFG at 350 ppmv. The concentrations of VOCs contained in LFG were estimated by using waste acceptance records, an understanding of the landfill’s operational and waste acceptance history, and the previously discussed NMOC concentration in LFG of 1,190 ppmv as hexane. This evaluation indicated that the landfill likely contained only MSW or contained very little organic commercial/industrial wastes. Accordingly, it is likely that co-disposal did not occur at the landfill. Guidance published by the U.S. EPA in Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (5th Edition including Supplements A, B and C), AP-42, Office of Air Quality Planning and Standards, (AP-42), Chapter 2: Solid Waste Disposal, Section 2.4, Municipal Solid Waste Landfills, Table 2.4-2 (11/1998) indicates that an appropriate VOC concentration in LFG for landfills without co-disposal is 39% of the NMOC concentration in LFG. Accordingly, VOC concentrations in LFG were estimated to be approximately 464 ppmv. Estimated fugitive emissions are summarized in the following table. These are based on the measured concentrations discussed above and 10% of the LFG generation being emitted fugitively from the Landfill. As the fugitive LFG emissions consist of uncombusted LFG, it has been assumed that there are no combustion emissions (SO2, NOx, PM, and CO) associated with this emissions source. Table 3-1 Fugitive Emissions from LandfillParameterLandfill Gas GenerationFugitive EmissionsMolecular WeightConcentration in Landfill Gas (ppmv)Landfill Generation (lb/scf)Landfill Generation (lb/hr)Fugitive Emissions (lb/hr)Fugitive Emissions (ton/year)NMOC (Flare / Fugitive)86.181,190 0.0002649919.9652881.9965298.7VOC (Flare / Fugitive)86.184640.000103347.7864620.7786463.4CAS - No.VOC (Y/N)HAP (Y/N)HAC (Y/N)Non-Methane Organic Compounds(NMOCs)71-55-6NYY1,1,1-Trichloroethane133.410.2010.000000070.0052200.0005220.0079-34-5YYY1,1,2,2-Tetrachloroethane167.850.0160.000000010.0005230.0000520.0079-00-5YYY1,1,2-Trichloroethane133.400.0040.000000000.0001040.0000100.0075-34-3YYY1,1-Dichloroethane98.970.3640.000000090.0070130.0007010.0075-35-4YYY1,1-Dichloroethene (Vinylidene Chloride) (1,1-Dichloroethylene)96.940.0160.000000000.0003020.0000300.00120-82-1YYN1,2,4-Trichlorobenzene181.450.0100.000000000.0003530.0000350.0095-63-6YNN1,2,4-Trimethylbenzene120.191.1990.000000370.0280550.0028050.01106-93-4YYY1,2-Dibromoethane (Ethylene dibromide)187.880.0080.000000000.0002930.0000290.0076-14-2NNY1,2-Dichloro-1,1,2,2-Tetrafluoroethane (Freon 114) (Dichlorotetrafluoroethane)170.920.0750.000000030.0024960.0002500.0095-50-1YNY1,2-Dichlorobenzene (o-dichlorobenzene)147.000.0030.000000000.0000860.0000090.00107-06-2YYY1,2-Dichloroethane (Ethylene Dichloride)98.960.0180.000000000.0003470.0000350.00156-60-5YNY1,2-Dichloroethene (Trans)96.940.2340.000000060.0044160.0004420.0078-87-5YYY1,2-Dichloropropane (Propylene Dichloride)112.990.0200.000000010.0004400.0000440.00106-46-7YYN1,4-Dichlorobenzene (p-dichlorobenzene)147.000.1190.000000050.0034060.0003410.0071-23-8YNY1-Propanol60.101.3250.000000210.0155030.0015500.01540-84-1YYN2,2,4-Trimethylpentane114.220.7170.000000210.0159430.0015940.01110-75-8YNY2-Chloroethoxyethene (2-Chloroethyl vinyl ether)106.550.0180.000000000.0003730.0000370.0067-63-0YNY2-Propanol (Isopropyl Alcohol)60.113.1450.000000490.0368040.0036800.02107-05-1YYY3-Chloroprene (Allyl chloride)76.530.0120.000000000.0001790.0000180.00108-10-1YYY4-Methyl-2-Pentanone (Methyl isobutyl ketone)100.160.6610.000000170.0128890.0012890.0167-64-1NNYAcetone58.086.560.000000980.0741740.0074170.03107-13-1YYYAcrylonitrile53.060.0360.000000000.0003720.0000370.00126-99-8YYYb-Chloroprene88.540.0170.000000000.0002930.0000290.0071-43-2YYYBenzene78.111.6590.000000330.0252280.0025230.0175-27-4YNYBromodichloromethane163.830.0160.000000010.0005100.0000510.0074-83-9YYYBromomethane (Methyl bromide)94.940.010.000000000.0001850.0000180.0075-15-0YYYCarbon disulfide76.130.3860.000000080.0057210.0005720.0056-23-5YYYCarbon tetrachloride153.840.0160.000000010.0004790.0000480.00463-58-1YYNCarbonyl sulfide60.070.0160.000000000.0001870.0000190.00108-90-7YYYChlorobenzene112.560.0680.000000020.0014900.0001490.0075-00-3YYNChloroethene (Ethyl Chloride)64.520.3740.000000060.0046980.0004700.0067-66-3YYYChloroform119.390.0210.000000010.0004880.0000490.0074-87-3YYYChloromethane (Methyl Chloride)50.490.0620.000000010.0006090.0000610.0098-82-8YYYCumene120.190.150.000000050.0035100.0003510.00110-82-7YNYCyclohexane84.180.510.000000110.0083580.0008360.00CAS - No.VOC (Y/N)HAP (Y/N)HAC (Y/N)Non-Methane Organic Compounds(NMOCs)124-18-5YNYDecane142.287.4950.000002760.2076050.0207600.09124-48-1YNYDibromochloromethane208.280.0060.000000000.0002430.0000240.0075-71-8NNYDichlorodifluoromethane120.911.720.000000540.0404870.0040490.0275-09-2NYYDichloromethane (Methylene Chloride)84.940.610.000000130.0100870.0010090.0064-17-5YNYEthanol (Ethyl Alcohol)46.086.5050.000000770.0583560.0058360.03141-78-6YNYEthyl Acetate88.111.0370.000000240.0177880.0017790.0175-08-1YNYEthyl mercaptan (Ethanethiol)62.130.0160.000000000.0001940.0000190.00100-41-4YYYEthylbenzene106.162.240.000000610.0462950.0046290.0275-69-4NNYFluorotrichloromethane (Freon-11) (Trichlorofluoromethane)137.381.1790.000000420.0315330.0031530.0150-00-0YYYFormaldehydeNot Applicable76-13-1NNYFreon 113 (1,1,2-Trichloro-1,2,2-trifluoroethane)187.380.0230.000000010.0008390.0000840.00142-82-5YNYHeptane100.203.750.000000970.0731510.0073150.03110-54-3YYYHexane86.183.0850.000000690.0517590.0051760.027783-06-4NNYHydrogen sulfide34.083500.000030822.3221470.2322151.027439-97-6NYYMercury200.610.0002920.000000000.0000110.0000010.0079-20-9YNYMethyl Acetate74.080.4470.000000090.0064470.0006450.0078-93-3YNYMethyl ethyl ketone72.1110.6050.000001980.1488770.0148880.0778-92-2YNYs-Butyl Alcohol/2-Butanol74.121.5240.000000290.0219910.0021990.01100-42-5YYYStyrene104.150.0380.000000010.0007700.0000770.0075-65-0YNYtert-Butanol (2-Methyl-2-Propanol) (t-Butyl alcohol)74.120.1140.000000020.0016450.0001640.00127-18-4NYYTetrachloroethylene165.830.3380.000000140.0109120.0010910.00109-99-9YNYTetrahydrofuran72.115.680.000001060.0797380.0079740.03108-88-3YYYToluene92.149.00.000002140.1614410.0161440.0779-01-6YYYTrichloroethylene (Trichloroethene)131.40.2170.000000070.0055510.0005550.0075-01-4YYYVinyl chloride62.500.700.000000110.0085170.0008520.00108-38-3/106-42-3 / 95-47-6YYYXylenes106.1610.060.000002760.2079130.0207910.09Total Quantified NMOCs?0.0000503.780.381.65Total Quantified VOCs?0.0000171.280.130.56Total Quantified HAPs?0.0000080.590.060.26Total Quantified HACs?0.0000483.650.361.603.2LFG Combustion Emissions Emissions from the combustion processes at the Facility, including the flares and the CAT G3520C engine were based on emission factors provided by manufacturers, site specific chemical analysis of the LFG, and emission factors published by the U.S. EPA in AP-42. Emissions estimates were performed using a spreadsheet named combined_caop12024 and caop16008.xlsx, and the estimations performed with this spreadsheet are summarized in the following tables. 3.2.1LFG Flare Emissions Emissions of CO and NOx for the landfill flares were based on emission factors provided by the flare manufacturers. Emissions of SO2 were estimated using a hydrogen sulfide (H2S) concentration of 350 ppmv as discussed above in Section 3.1. The Facility installed a H2S removal system in 2013, but based on information contained in the 2016 registration data, this system has been operated infrequently. Accordingly, it was assumed that the H2S concentration in combusted LFG would be 350 ppmv, rather than some lower concentration that may have been achieved by continuous use of the H2S removal system. VOC and HAP emissions were based on estimates presented in the Application for AOP-12-024, an assumed 90% collection efficiency for the LFG collection system, and an assumed 98% destruction efficiency in the combustion devices at the Facility. The VOC concentrations in LFG were estimated to be 1.03E-04 lb VOC/scf of LFG, and HAP concentrations in LFG were estimated to be 7.88E-6 lb HAPs/scf of LFG. Emissions of PM were estimated using the 15 lb/MMscf-methane from AP-42 that was presented in the application for AOP-12-024, an assumed methane concentration of 50 percent in LFG, and an assumed heat value for LFG of 500 Btu/scf. Using these values, the emission factor for flares firing LFG at the Landfill Operation is 0.015 lb/MMBtu, plus an additional factor to account for the silicon dioxide (SiO2) PM created from the combustion of siloxanes in the LFG. The amounts of siloxanes used in consumer products and construction materials have generally increased over the last two decades, and the AP-42 emission factors for flares are based on data for landfills that, to the Agency’s understanding, have lower siloxane contents when compared to the LFG generated from landfill operations that have recently accepted waste material. To account for this difference in siloxane concentrations, a separate factor was added to the AP-42 PM emission. This additional PM emission factor was estimated based on the assumption that untreated LFG contains 10 milligrams of silicon per cubic meter (mg Si/m3), and that all the Si contained in the LFG is oxidized to SiO2 with an aerodynamic diameter that is less than the 60 ?m PM threshold. Based on these assumptions, the LFG will produce 0.003 pounds of PM per million Btu of LFG. The emission factor for the flares will be the sum of these two factors (0.015 lb/MMBtu + 0.003 lb) or 0.018 lb/MMBtu. Flare combustion emissions were estimated for two different operating conditions. One condition was for the entire estimated amount of collected LFG (1,130 scfm) to be combusted in the flares. The other condition assumed that 580 scfm of LFG was combusted in the flares, while the CAT G3520C engine at the LFGTE Operation combusted the remaining 550 scfm of collected LFG. Table 3-2 - Estimated Emissions from Landfill Operation FlaresCombustion of 1,130 scfm of LFG (All Collected LFG)PollutantEmission FactorEstimated Emissions (tons per year)FactorUnits ReferenceSO20.118lb/MMBtu 1Site Specific Data - Maximum reported H2S Concentration in LFG from 2016 Registration data. 17.59NOx39lb/MMcf methaneVendor Supplied – Application for #AOP-12-0245.79PM0.018lb/MMBtu 1AP-42, Municipal Solid Waste Landfills, Table 2.4-5 (11/98) plus PM emissions from siloxane combustion2.67CO46lb/MMcf methaneVendor Supplied – Application for #AOP-12-0246.83VOC4.12E-03lb/MMBtu 1Site Specific Data - Application for #AOP-12-0250.612HAPs3.15E-04lb/MMBtu 10.0471 lb/MMBtu equals pounds of pollutant emitted per million British thermal units of heat input. 2 lb/MMcf methane equals pounds of pollutant emitted per million cubic feet of methane input. Table 3-3 - Estimated Emissions from Landfill Operation FlareCombustion of 580 scfm of LFG (All Collected LFG less 550 scfm to CAT 3520C Engine)PollutantEmission FactorEstimated Emissions (tons per year)FactorUnitsSourceSO20.118lb/MMBtu 1Site Specific Data - Maximum reported H2S Concentration in LFG from 2016 Registration data. 9.03NOx39lb/MMcf methaneVendor Supplied – Application for #AOP-12-0242.97PM0.018lb/MMBtu 1AP-42, Municipal Solid Waste Landfills, Table 2.4-5 (11/98) plus PM emissions from siloxane combustion1.37CO46lb/MMcf methaneVendor Supplied – Application for #AOP-12-0243.51VOC4.12E-03lb/MMBtu 1Site Specific Data - Application for #AOP-12-0250.314HAPs3.15E-04lb/MMBtu 10.0241 lb/MMBtu equals pounds of pollutant emitted per million British thermal units of heat input. 2 lb/MMcf methane equals pounds of pollutant emitted per million cubic feet of methane input. 3.2.2Reciprocating Internal Combustion Engine Combustion Emissions CAT 3520C EngineEmissions of NOx for the CAT 3520C LE engine was based on emission guarantees provided by the engine manufacturer, and emissions of CO were based on the revised MSER for this engine, which is a not-to-exceed emission rate of 3.5 g/bhp-hr. Emissions of PM were estimated using the PM emission limitation of 0.2 g/bhp-hr proposed in the Application for AOP-08-015. With the exception of formaldehyde, VOC and HAP emissions were based on estimates presented in the Application for AOP-12-025, and an assumed 98% destruction efficiency in the combustion devices at the Facility. Total LFG flow through the CAT 3520C LE engine is estimated at 550 scfm. The CAT 3520C engine is nominally rated at 2,233 bhp. The VOC concentrations in LFG were estimated to be 1.03E-04 lb VOC/scf of LFG, and HAP concentrations in LFG were estimated to be 7.88E-6 lb HAPs/scf of LFG. Based on these assumptions, the VOC and HAP emission factors for the CAT 3520C engine, (excluding formaldehyde) are estimated at 0.014 g/bhp-hr and 0.001 g/bhp-hr, respectively. Formaldehyde is formed in the engine as a product of incomplete combustion, and the formaldehyde emissions were based on a formaldehyde emission factor of 5.28E-02 lb/MMBtu of heat input obtained from AP-42, Chapter 3: Stationary Internal Combustion Sources, Section 3.2, Natural Gas-fired Reciprocating Engines, Table 3.2-2 Uncontrolled Emission Factors for 4-Stroke Lean-Burn Engines, (Supplement F, August 2000), and by assuming a fuel heat value of 500 Btu/scf, and an LFG supply rate to each engine of 550 scf of LFG. This results in an estimated emission factor for formaldehyde of 0.177 g/bhp-hr. The VOC and HAP emission factors for the CAT 3520C engine including formaldehyde are therefore 0.191 g/bhp-hr and 0.178 g/bhp-hr, respectively. It should be noted that these emission factors appear to be less than those obtained for similar engines operating on LFG. To provide a better estimate of the VOC and HAP emission factors for the CAT 3520C engine at the LFGTE Operation, stack testing will be required to develop emission factors for compliance. The estimated emissions of a single HAP (formaldehyde) are less than 10 tons per year, and the estimated total HAP emissions are less than 25 tons per year, classifying the Facility as an area source of HAPs. Estimated emissions from the CAT 3520C engine and emission factors used for these estimates are summarized in Table 3.4. Table 3-4 – Estimated Emissions from One (1) CAT 3520C EngineCombustion of 550 scfm of LFG-PollutantEmission FactorAllowable Emissionstons per yearFactorUnitsSourceSO20.40g/bhp-hr 1Site Specific Data - Maximum reported H2S Concentration in LFG from 2016 Registration data. 8.56NOx0.5Vendor Supplied – Application for #AOP-08-01510.78PM0.20Site Specific Data - Application for #AOP-08-0154.31CO3.5MSER Limit for AOP-11-01275.47VOC0.191Site Specific Data - Application for #AOP-12-0254.12HAPs0.178Site Specific Data - Application for #AOP-12-0253.841 g/bhphr equals grams of pollutant emitted per brake horsepower hour at rated load and speed.Landfill Operation – LPG Heaters and Portable Power UnitsThe Application for #AOP-12-024 indicated that there were three LPG-fired heaters and several portable electrical generators at the Landfill Operation. The Agency has determined that these LPG-fired heaters are an insignificant source of emissions at the Facility. No indication was provided regarding the age or emissions certifications for these portable electrical generators. As the engines associated with this equipment are non-road engines, they are not subject to regulations that apply to stationary engines. However, if these engines remain in a single fixed location for greater than 12-months, they will be considered stationary engines. Based on the Agency’s understanding of the activities at the Landfill Operation, the Agency has determined that it would not be appropriate to include the emissions from these engines in the emissions estimates for the Facility. These engines are non-road engines, likely of recent vintage, and with limited hours of operation and limited fuel usage. 3.3Facility Greenhouse Gas (GHG) EmissionsThe Facility has emissions of GHGs resulting from biological generation of CH4 and CO2 in the Landfill itself, and GHGs generated from the combustion of CH4 contained in collected LFG. Biogenic CO2 includes the CO2 formed in the landfill and CO2 resulting from the combustion of CH4 formed in the landfill. Emissions of CH4 from the landfill as fugitive emissions or as uncombusted CH4 in the exhausts from the control devices (flares and/or the CAT 3520C engine) is considered a non-biogenic emission. Nitrous oxide (N2O) is also formed during combustion processes and is considered a GHG. However, even considering the global warming potential of (GWP) of N2O which is approximately 298, the effect of N2O emissions on total GHG emissions was considered to be negligible, and accordingly was not estimated. Emissions include actual CO2 emissions, and emissions of CH4 adjusted to CO2 equivalent (CO2e). The GWP of CH4 was assumed to be 25. Emissions of GHG’s are presented in Table 3-6 for both total GHG emissions, and exclusive of biogenic CO2 emissions. Table 3-6 – Estimated Total Facility GHG Emissions Pollutant GWPEmissions by Emissions Source (tons per year)Total Estimated Emissions (tons/year)Total Estimated Emissions (tons/year CO2e)Fugitive EmissionsFlare Combustion EmissionsCollected CO2 Emitted from FlareEngine Combustion EmissionsCollected CO2 Emitted from EngineCO21 1,5018,4946,9338,0526,57331,55331,553CH425 682.263---60--- 805---CO2e of CH4 Emissions17,0541,576---1,494------20,124CO2e Emissions---18,55510,0696,9339,5466,57351,6773.4Combined Facility EmissionsEmissions from the Facility for fugitive LFG emissions and for both combustion scenarios (all LFG through the flares OR the CAT 3520C engine running at full capacity with the balance of LFG through a flare) are tabulated in Table 3-7. The scenario that resulted in the greatest emissions for a particular pollutant was used to establish allowable emissions. The aggregated emissions of VOCs and HAPs from fugitive landfill emissions are also presented in this table, and are included in the proposed allowable emissions. Emissions of individual HAPs/HACs from the Facility are discussed in greater detail in Section 7. Table 3-7 – Estimated and Allowable Emissions Summary (ton/yr)ActivityPM / PM10/PM2.5SO2 NOx CO VOC2 HAPFugitive Emissions - Landfill------------3.4100.260Combustion Emissions Scenario A:All Collected LFG Combusted in Flares2.6717.595.796.830.6120.047Scenario B:One (1) CAT 3520C Engine 4.318.5610.7875.474.1183.838Balance of LFG Combusted in Flare(s)1.379.032.973.510.3140.024Total Estimated Emissions5.6817.5913.7578.987.8434.122Allowable Emissions 15.717.613.879<25<10/251 The Agency and Permittee have proposed to limit allowable PM emissions to less than 5.7 tpy, allowable SO2 emissions to less than 17.6 tpy, and allowable VOC emissions <25 tons per year. 4.0.APPLICABLE REQUIREMENTSPursuant to §5-1006(e)(4) of the Regulations, the Owner and/or Operator of a stationary air contaminant source applying for a Permit to Operate is required to identify and certify compliance with all applicable state and federal air pollution control requirements before a permit may be issued. These requirements include state and federal regulations, state statutes, the federal Clean Air Act, and the requirements of any construction permit issued under 10 V.S.A. §556 and §5-501 of the Regulations. Applicable federal regulations may include Federal New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAP) found in 40 CFR, Parts 60, 61, and 63. The applicable requirements and the Agency's findings are presented below. Applicability of §5-261 (Control of Hazardous Air Contaminants) is discussed separately under Section 8 below.The Agency will assess compliance with these regulations during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of equipment and air pollution control devices, visual observations of emission points, and review of any records required by the Permit4.1Vermont Air Pollution Control Regulations and Statutes§§5-201, 5-202, and 5-203 - Open Burning Prohibited. "No person shall engage in any open burning except in conformity with the provisions of Sections 5-201, 5-202, and 5-203".Based on the application submittal, and information available to the Agency, no open burning is conducted at the Facility.§5-211(1) - Prohibition of Visible Air Contaminants - Installations constructed prior to April 30, 1970. "No person shall cause, suffer, allow or permit the emission of any visible air contaminant from installations constructed prior to April 30, 1970, for more than a period or periods aggregating six (6) minutes in any hour, which has a shade, or density, greater than 40% opacity (No. 2 on the Ringelmann Chart). At no time shall the visible air contaminants have a shade, density, or appearance greater than 60% opacity (No. 3 of the Ringelmann Chart).”These emission standards do not apply to the Facility, as the entire Facility was constructed subsequent to 1970. §5-211(2) - Prohibition of Visible Air Contaminants - Installations constructed subsequent to April 30, 1970. "No person shall cause, suffer, allow or permit the emission of any visible air contaminant from installations constructed subsequent to April 30, 1970, for more than a period or periods aggregating six (6) minutes in any hour, which has a shade, or density, greater than 20% opacity (No. 1 of the Ringelmann Chart). At no time shall the visible air contaminants have a shade, density, or appearance greater than 60% opacity (No. 3 of the Ringelmann Chart)." These emission standards apply to all installations at the Facility as the entire Facility was constructed subsequent to 1970. The applicant is anticipated to comply with these emission standards based on proper equipment design, operation and maintenance.Any emission testing conducted to demonstrate compliance with the above emission limits shall be performed in accordance with 40 CFR Part 51, Appendix M, Methods 203B and 203C, respectively, or equivalent methods approved in writing by the Agency§5-221(1)(a) - Prohibition of Potentially Polluting Materials in Fuel. "No person shall cause or permit the use, purchase, or sale for use in stationary combustion installations within the State of Vermont for heat or power generation of:, Fuels containing more than 2.0% sulfur by weight, except as otherwise provided below; No. 2 and lighter distillate oils and animal and vegetable fuel oils with a sulfur content greater than 0.05% by weight beginning on July 1, 2014, and ending on June 30, 2018;No. 2 and lighter distillate oils and animal and vegetable fuel oils with a sulfur content greater than 0.0015% by weight, beginning on July 1, 2018 No. 4 residual oil with a sulfur content greater than 0.25% by weight, beginning on July 1, 2018; and No. 5 and No. 6 residual oils and heavier residual oils and used oils with a sulfur content greater than 0.5% by weight, beginning on July 1, pliance with this standard for liquid fossil fuels is based on fuel analyses following the procedures prescribed by the American Society of Testing Materials ("ASTM").This regulation applies to all stationary fuel burning equipment at the Facility including the CAT G3520C LE engine fired with LFG, all LFG flares, the LPG-fired space heating units, and the portable generating units that are used solely at the Facility, and that remain within the Facility boundaries. The Permittee is anticipated to comply with this regulation. LPG, by its fuel specification, complies with the requirements of this regulation. The concentration of H2S in LFG will be regularly monitored to maintain SO2 emissions at less than 17.6 tons per year, and with this limitation, the LFG will be less than 2.0 percent sulfur by weight. Permit conditions will restrict the sulfur content of diesel fuel used in the portable generators at the facility to the requirements for ultra-low diesel fuel, which contains less than 0.0015% by weight (15 ppm) of sulfur. §5-231(2) - Prohibition of Particulate Matter; Incinerator Emissions. An "Incinerator" is defined in §5-101 of the Regulations as “any structure or furnace in which combustion takes place, the primary purpose of which is the reduction in volume and weight of an unwanted material.” The landfill utility flares may be considered such a device. The CAT 3520C engine at the LFGTE Operation is used to produce electric power, and accordingly is not regulated as an incinerator in accordance with §5-231(2)(d). PM emission limits for incinerators with a charging rate of less than 50 tons per day are defined §5-231(2)(a), and this limit is 0.1 pounds of PM per 100 pounds of refuse burnt (0.001 lb PM/pound refuse combusted). Incinerators with a charging rate of greater than 50 tons per day are limited to emissions of particulate matter not exceeding 0.08 grains per dry standard cubic foot corrected to 12 percent carbon dioxide. The estimated LFG mass flowrate (assuming 50 percent CH4, 40 percent CO2, and 10 percent N, with a weight of 0.074 lb/scf) to the LFG Specialties flare for a flowrate of 1,130 scfm of LFG is approximately 4,993 pounds per hour. Accordingly, the daily LFG flowrate would be approximately 60 tons per day, which is greater than 50 tons per day. PM emissions from the assumed single flare at the emission limit of 0.018 lb/MMBtu of heat input with a flowrate of 1,130 scfm are estimated to be 0.61 pounds per hour, and flare emissions have been estimated to be approximately 12,500 scfm. This would result in an emission rate of approximately 0.006 gr/dscf of exhaust gas. Accordingly, the emissions from the flares are anticipated to comply with this regulation. §5-231(3)(a) - Prohibition of Particulate Matter; Combustion Contaminants. "A person shall not discharge, cause, suffer, allow or permit the emission of particulate matter caused by the combustion of fossil fuel in fuel burning equipment from any stack or chimney in excess of the following emission limits:(i)0.5 pounds per hour per million BTUs of heat input in combustion installations where the heat input is 10 million BTUs or less per hour.(ii)For combustion installations where the heat input is greater than 10 million BTUs per hour, but where the heat input is equal to or less than 250 million BTUs per hour, the applicable limit is determined by using the following formula:where:EPM -is the particulate matter emission limit, expressed to the nearest hundredth pound per hour per million BTUs; andHI -is the heat input in millions of BTUs per hour."Compliance with this emission standard shall be determined in accordance with 40 CFR, Part 60, Appendix A, Reference Method 5 or an alternative method approved in writing by the Agency.This emission standard applies to the LPG-fired heating units, and the non-road portable electrical generators at the Facility, which have a heat input of less than 10 MMBtu/hr, and consequently an emission limitation of 0.5 pounds per hour per MMBtu of heat input will apply to these heating units. The Agency has previously determined that the utility flares and the CAT G3520C engine at the Facility are not subject to this requirement, as LFG is not a fossil fuel, and the Facility is shielded from this requirement. §5-231(4) - Prohibition of Particulate Matter; Fugitive Particulate Matter. ."A person shall not cause, suffer, allow, or permit any process operation to operate that is not equipped with a fugitive particulate matter control system. A person shall not cause, suffer, allow, or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired or demolished without taking reasonable precautions to prevent particulate matter from becoming airborne. Public roads will not be subject to this section unless a public nuisance is created."This requirement applies to the entire Facility, and the Facility is therefore anticipated to comply with the fugitive emission limitations of this section.§5-241(1) and (2) - Prohibition of Nuisance and Odor. "A person shall not discharge, cause, suffer, allow, or permit from any source whatsoever such quantities of air contaminants or other material which will cause injury, detriment, nuisance or annoyance to any considerable number of people or to the public or which endangers the comfort, repose, health or safety of any such persons or the public or which causes or has a natural tendency to cause injury or damage to business or property. A person shall not discharge, cause, suffer, allow, or permit any emissions of objectionable odors beyond the property line of a premises."When the Landfill Operation was receiving waste, there were numerous complaints regarding odors from the Facility. However, as the Landfill Operation is closed to waste acceptance, and based on the application submittal and recent information available to the Agency, the Facility is currently in compliance with this regulation. §5-403 - Circumvention. "No Person shall build, erect, install or use any article, machine, equipment or other contrivances, the use of which, without resulting in a reduction in the total release of air contaminants to the atmosphere, reduces or conceals an emission which otherwise would constitute a violation of these regulations."Based on the application submittal and information available to the Agency, the Facility is currently in compliance with this regulation.Subchapter VIII - Registration of Air Contaminant Source. "Each operator of a source which emits more than five tons of any and all air contaminants per year shall register the source with the Secretary, and shall renew such registration annually."Both MLI and EPP have been registering the Facility emissions with the Agency annually, and each Permittee will be responsible for registering their emissions from the Facility that are described in their individual Permits. 4.2.Federal Air Pollution Control Regulations and the CAASection 111 of the Clean Air Act establishes New Source Performance Standards (NSPS). NSPSs apply to new sources, and are promulgated under 40 CFR, Part 60. Section 112 of the Clean Air Act establishes National Emission Standards for Hazardous Air Pollutants (NESHAPs). NESHAPs are promulgated under 40 C.F.R. Part 61 and Part 63, and may apply to new or existing sources. Potentially applicable NSPSs and NESHAPs are summarized in Table 4-2.Table 4-2 Review of Requirements fromFederal Regulations and the Clean Air Act40 CFR Part 60 Subpart Cc – Emission Guidelines for Municipal Solid Waste Landfills. Applies to existing landfills which commenced construction, modification, or reconstruction before May 30, 1991, and that have accepted waste at any time since November 8, 1987, or have additional capacity for future waste deposition. This regulation is not applicable to the Facility. The Landfill Operation was modified subsequent to May 30, 1991 to increase its capacity, thus becoming subject to 40 CFR Part 60 Subpart WWW. 40 CFR Part 60, Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984. Applicability: The affected facility to which this subpart applies is each storage vessel with a capacity greater than or equal to 75 m3 (19,804 gal) that is used to store volatile organic liquids (including petroleum). This subpart does not apply to the following:1.Any storage vessel with a capacity less than 75 m32.Any storage vessel storing a liquid with a vapor pressure less than 3.5 kPa3.Any storage vessel with a capacity > 75 m3 and <151 m3 with a v.p. <15.0 kPa4.Pressure vessels >29.7 psi and without emissions to the atmosphere. 5.Vessels permanently attached to mobile vehicles.6.Vessels located at bulk gasoline plants.7.Vessels located at gasoline service stations.For affected facilities, there are recordkeeping requirements and depending upon the material stored there may be standards for the tank’s vent system.The storage tanks at the Facility are used to store No. 2 fuel oil, new and used engine oil, and landfill leachate, all of which have a vapour pressure of less than 3.5 kPa. Accordingly, the Facility has no storage tanks subject to this regulation.40 CFR Part 60, Subpart WWW - Standards of Performance for Municipal Solid Waste Landfills. §60.752 Standards - Requires landfill gas collection and control system. §60.753 Operational Standards - Operational requirements of the gas collection and control system. Applicable to all MSW landfills with a design capacity of 2.5 million mega-grams (Mg) or greater, however the requirement to install the landfill gas collection and control system is only required once uncontrolled emissions of nonmethane organic compounds (NMOCs) from the landfill equal or exceed 50 Mg/year. The Facility is not subject to this regulation. The Landfill Operation has a design capacity at closure (unlined and Phase 1, 2, and 3) of approximately 2.26 million Mg. The Agency is imposing emission controls on the Landfill Operation that are substantially equivalent to Subpart WWW under the authority of 5-261 of the Regulations.40 CFR Part 60, Subpart XXX - Standards of Performance for Municipal Solid Waste Landfills. The provisions of this subpart apply to each municipal solid waste landfill that commenced construction, reconstruction, or modification after July 17, 2014. This regulation imposes various notification and reporting requirements, and monitoring and operational controls for landfills exceeding certain capacity and emission thresholds. Requires the submittal of a design capacity report for landfills with a design capacity less than 2.5 million megagrams by mass or 2.5 million cubic meters by volume. For landfills with a design capacity of equal to or greater than 2.5 million megagrams and 2.5 million cubic meters, the NMOC emission rate from the landfill must be calculated annually using the procedures specified in §60.764. Requires the installation of a landfill gas collection and control system once uncontrolled emissions of nonmethane organic compounds (NMOCs) from the landfill equal or exceed 34 Mg/year. The Facility is not subject to this regulation. The Landfill Operation ceased accepting waste on July 15, 2013, which predates the applicability date of Subpart XXX. The Agency is imposing emission controls on the Landfill Operation that are substantially equivalent to Subpart XXX under the authority of 5-261 of the Regulations. 40 CFR Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE). Applies to CI RICE model year 2007 and later as well as those ordered after July 11, 2005 and with an engine manufacture date after April 1, 2006. This standard also applies to stationary CI RICE that are modified or reconstructed after July 11, 2005. This regulation established emission rates for affected engines, requires routine engine maintenance and sets maximum sulfur content for the diesel fuel. Beginning October 1, 2010 applicable engines shall only use diesel fuel with a maximum sulfur content of 15 ppm (ULSD). Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. It is anticipated that this regulation is not applicable to the CAT 3520C engine at the LFGTE Operation as this engine is spark ignition rather than compression ignition. The diesel-fueled compression ignition engines powering the portable generators at the Landfill Operation are currently not subject to Subpart IIII, but if they are used in a fashion where they would be considered stationary engines, and if these engines are model year 2007 or newer, then these engines will be subject to the emissions limitations and certification requirements of Subpart IIII. 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. Applies to new spark ignition engines installed after June 12, 2006. Engines greater than 100 bhp firing landfill or digester gas must meet emission limits for NOx, CO and VOC and, for units 500 bhp and less, shall have a one-time compliance test and, for units greater than 500 bhp, shall have a compliance test at least once every 8,760 hours of operation or every 3 years, whichever occurs first. Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart JJJJ is anticipated to be applicable to the CAT 3520C engine at the LFGTE Operation. The gasoline-fueled spark ignition engines powering the portable generators at the Landfill Operation are currently not subject to Subpart IIII, but if they are used in a fashion where it would be considered a stationary engine, and if this engine is model year 2007 or newer, then this engine will be subject to the emissions limitations and certification requirements of Subpart JJJJ. 40 CFR Part 61, Subpart M - National Emission Standards for Hazardous Air Pollutants: National Emission Standard for Asbestos. Applies to: the owner or operator of a demolition or renovation activity, including regulated asbestos-containing material (RACM) demolition and renovation operations, which are regulated under §61.145 of this Subpart. Waste generated from these activities shall be disposed on in accordance with the requirements of §61.150 of this Subpart. Waste disposal facilities receiving waste that is to be disposed of in accordance with §61.150 of this Subpart shall be operated in accordance with the provisions of §61.154 of this Subpart. Waste disposal facilities subject to this rule, shall be operated with no visible emissions to the outside air from areas of RACM disposal, or shall have barriers and signage restricting access to areas of RACM disposal, or shall cover areas of RACM disposal on a daily basis. Waste disposal facilities receiving RACM shall also maintain records of material receipt and shall submit records to the Administrator identifying areas of RACM disposal upon closure of the landfill, and shall notify the Administrator prior to disturbing areas of RACM disposal. Subpart M is anticipated to apply to the Facility, specifically to the recordkeeping and post-closure notification requirements regarding the disposal of RACM at the Landfill Operation.40 CFR Part 63, Subpart AAAA - National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills. §63.1955 Standards - Requires gas collection and control system meeting the same standards as 40 CFR Part 60, Subpart WWW by referencing such. Applicable to all MSW landfills that are: a major source of Hazardous Air Pollutants (HAPs), orare collocated with a major source of HAPs, or are an area source with a design capacity of 2.5 million megagrams (Mg) or greater and have estimated uncontrolled emissions of NMOCs equal to or greater than 50 Mg/year. The Facility is not subject to this regulation. The combined HAP emissions from the Landfill Operation and the LFGTE Operation are less than the major HAP source thresholds, and the Landfill Operation does not have a design capacity of 2.5 million megagrams (Mg) or greater. The Agency is imposing emission controls on the Landfill Operation that are substantially equivalent to Subpart AAAA under the authority of 5-261 of the Regulations.40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. Applies to new engines that commenced construction (installed) on or after June 12, 2006 at area sources of HAPs. Requires such engines to comply with NSPS Subpart IIII or JJJJ, as applicable. Also, applies to existing engines that commenced construction (installed) prior to June 12, 2006 at area sources of HAPs. By May 3, 2013 requires engines equal and greater than 300 bhp to meet CO emission standards which may necessitate catalytic controls, must install crankcase ventilation system, and requires ULSD fuel. Engines <300 bhp need only meet maintenance requirements including changing oil & filter and, inspecting and replacing if necessary, air filter, hoses and belts. Does not apply to existing emergency units at an area source residential/commercial/institutional facility unless they are enrolled in demand response programs. Subject emergency units are subject to maintenance requirements, must install an elapsed hour meter and must use ULSD commencing January 1, 2015 if used for DR. For engines firing landfill or digester gas comprising 10% or more of the heat input, the engines are subject to management practices only (change oil & filter, inspect plugs, and inspect hoses and belts every 1440 hours or annually, whichever occurs first) as well as operating in accordance with manufacturer’s recommendations and minimizing time at idle. Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart ZZZZ is anticipated to apply to the CAT G3520C engine at the LFGTE Operation. Since the CAT G3520C engine at the LFGTE Operation commenced construction and was installed on or after June 12, 2006, this engine will comply with the new engine requirements of Subpart ZZZZ by complying with 40 CFR Part 60, Subpart JJJJ. The remaining engines powering the portable generators at the Landfill Operation are rated at less than 300 bhp each, and are currently not subject to Subpart ZZZZ. If these engines are used in a fashion where they would be considered stationary engines, and if Subpart ZZZZ applies to these engines, they will be subject to the maintenance standards identified above. Clean Air Act §112r Prevention of Accidental Release; 40 CFR Part 68 Chemical Accident Prevention Programs. Facilities that have more than the threshold quantity of a regulated substance in a process are subject to these provisions including the requirements to conduct a hazard assessment, establish a prevention program and develop a risk management plan.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. The Permittee has stated that the Facility does not have more than the threshold quantity of a regulated substance and thus is not subject to these requirements. Clean Air Act §608 National recycling and emission reduction program; 40 CFR Part 82,Protection of Stratospheric Ozone, Subpart F – Recycling and Emissions Reductions. These requirement are applicable to any facility that owns, services, maintains, repairs, and disposes of appliances containing ozone depleting substances. Requirements of the regulation include, but are not limited to: (a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices specified in 40 CFR Part 82, Subpart F §82.156.(b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment as specified in 40 CFR Part 82, Subpart F §82.158.(c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program as specified in 40 CFR Part 82, Subpart F §82.161.(d) Commercial or industrial process refrigeration equipment must comply with the leak repair requirements specified in 40 CFR Part 82, Subpart F §82.156.(e) For each appliance normally containing fifty (50) or more pounds of refrigerant, the Permittee shall keep records of refrigerant purchased and added to such appliances as specified in 40 CFR Part 82, Subpart F §82.166.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. The Facility is anticipated to have subject equipment or operations applicable to this regulation.40 CFR Part 98 Mandatory Greenhouse Gas Reporting. Requires reporting of GHG emissions annually to EPA for: 1) Facilities in source categories listed in §98.2(a)(1) including electric utility units subject to Acid Rain, MSW landfills that generate CH4 in amounts equivalent to 25,000 metric tons of CO2e or more per year and electrical transmission and distribution equipment at facilities where the total nameplate capacity of SF6 and PFC containing equipment exceeds 17,820 pounds, 2) Facilities in source categories listed in §98.2(a)(2) including electronics manufacturing, iron and steel production and pulp and paper manufacturing that emit 25,000 metric tons of CO2e or more per year from such source categories as well as all stationary combustion, 3) Facilities with stationary combustion sources that aggregate to 30 MMBTU/hr or more and which emit 25,000 metric tons of CO2e or more per year from all stationary combustion sources combined, and 4) Fuel suppliers including all local natural gas distribution companies.The U.S. EPA has retained the implementing authority for this regulation and is responsible for determining applicability. This regulation under Part 98 is not considered to be an applicable requirement per 40 CFR Part 70.2 and as noted in 74 FR 56260 (October 30, 2009). Part 98 is anticipated to apply to the Landfill Operation at the Facility and MLI has been reporting emissions for applicable years.C.Non-Applicable Requirements for Which a Permit Shield Provision Has Been RequestedPursuant to §5-1015(a)(14) of the Regulations, the Owner/Operator may request a permit shield from specific state or federally enforceable regulations and standards which are not applicable to the source. The Permittee has requested a permit shield with respect to several potentially applicable requirements. The Agency has reviewed this request also reviewed permit shields for other landfill and landfill gas to energy facilities in Vermont. Based on this review the Agency is hereby granting a permit shield in accordance with §5-1015(a)(14) of the Regulations for the following requirements which have been determined not to be applicable to the Facility based on the understanding of activities at these types of operations and on information provided by the Permittee.Table 4-3 Non-Applicable Requirements for which a Permit Shield is Granted§5-231(1) - Prohibition of Particulate Matter: Industrial Process Emissions. The Agency has determined that the combustion of LFG is not considered an industrial process since gaseous fuels are not considered part of the process weight input into a process. Therefore, the combustion of LFG is not subject to this regulation§5-231(3) - Prohibition of Particulate Matter: Combustion Contaminants. The Agency has determined that LFG is not a fossil fuel under the definition in the Regulations therefore this regulation is not applicable to flares or engines that combust LFG. However, the other fuel burning equipment at the facility including the No.2 fuel oil space heating units, the used oil furnace, and the backup generator at the LFGTE Operation are subject. §5-241(2) - Prohibition of Nuisance and Odor: Control of Odors from Industrial Processes. While the Facility is subject to §5-241(1),the Agency has not previously classified all landfills as industrial processes subject to §5-241 and does not currently consider the Facility subject to this regulation. This regulation may become applicable at any point in the future upon a determination by the Air Pollution Control Officer that operations at the site are an odiferous process per se. In addition, in order to ensure compliance with other applicable requirements for this Facility, most of these emission control measures are required under separate authority. 5-271 – Control of Air Contaminants from Stationary Reciprocating Internal Combustion Engines. The Agency has determined that landfill gas is not a fossil fuel under the definition in the Regulations therefore this regulation is not applicable to engines that combust landfill gas5.0CONTROL TECHNOLOGY REVIEW FOR MAJOR SOURCES AND MAJOR MODIFICATIONSPursuant to §5-502 of the Regulations each new major source and major modification must apply control technology adequate to achieve the Most Stringent Emission Rate ("MSER") with respect to those air contaminants for which there would be a major or significant emission increase, respectively. The Permittee has not proposed any modifications to the Facility in conjunction with the review for this Permit to Operate and therefore is not subject to review under the MSER requirements in §5-502 of the Regulations at this time. Operating experience at this and other landfills has since shown that siloxane compounds present in the LFG, when combusted, result in the continuous formation of cement-like deposits on the internal engine components and the accumulation of these deposits results in increasing CO emissions over time. While these deposits can be periodically removed from the engine, CO emissions in the interim are anticipated to continuously increase. The engine manufacturer recommends annual cleaning of these deposits from the engine components followed by a more extensive on-site in-frame cleaning every three years and an even more extensive off-site overhaul every 6 years. Treatment options for the combustion gases are generally not practicable, as the siliceous deposits from siloxane combustion would likely render any catalytic control device ineffective. Accordingly, the previous MSER for CO the CAT 3520C LE engine, which is as follows, is re-established as part of #AOP-16-008:3.5 g/bhp-hr and 17.3 lb/hr (each) applies at all times3.1 g/bhp-hr and 15.3 lb/hr (each) must be demonstrated every two years. The permit may not require each engine to be tested each year in which case the results of those being tested will be considered representative of those not tested that year. 2.75 g/bhp-hr and 13.5 lbs/hour (each) must be demonstrated every 6 yearsThe flares were not previously considered as part of the MSER for the Facility, as only emission sources directly associated with the LFGTE Operation were evaluated in the original MSER analysis. The application for #AOP-12-024 indicated a CO emission limit for existing and proposed flare(s) at the Landfill Operation of 0.37 lb/MMBtu. This emission limit is consistent with flares at other facilities that combust LFG, and accordingly, the flares at the Landfill Operation will be required to meet this standard as MSER for the flare(s) at the Facility. . 6.0.AMBIENT AIR QUALITY IMPACT EVALUATIONThe Agency's implementation procedures concerning the need for an ambient air quality impact evaluation under §5-501 of the Regulations specifies that such analyses shall be performed when modifications result in an allowable emissions increase of 10 tpy or more of any air contaminant, excluding VOCs. Air quality impact evaluations are not required by the Agency for individual sources of VOCs. The Permittee has not proposed any modifications to the Facility in conjunction with the review for this Permit to Operate and therefore is not subject to an air quality impact analysis under §5-501 of the Regulations at this time. Prior Air Quality Impact Evaluations: Based on the originally proposed level of emissions from this Facility, the Agency required an AQIE for the pollutants CO, NOx, and SO2 as part of the review for the initial permit approved on September 15, 2008, and for modifications to the Facility approved on July 12, 2012. The modifications to the Facility approved on July 12, 2012 included revising the MSER for CO, and an AQIE was conducted for the pollutant CO. The Facility was found to comply with all applicable ambient air quality standards and prevention of significant deterioration increments for the initial permit approved on September 15, 2008, and for modifications to the Facility approved on July 12, 2012. Ambient Air Quality Impact EvaluationPermit #AOP-11-012 – July 12, 2012Comparison of Facility’s Impacts to National Ambient Air Quality Standards1PollutantAveraging time of Std.Ambient Standard (ug/m3)Modeled Impact of Facility(ug/m3)Background Value2(ug/m3)Total Impact w/ Background(ug/m3)CO1-hour40,0004473,6644,111CO8-hour10,0003872,5192,906Ambient Air Quality Impact EvaluationPermit #AOP-08-015 – September 15, 2008Comparison of Facility’s Impacts to National Ambient Air Quality Standards1PollutantAveraging Time of Standard.Ambient Standard (?g/m3)Modeled Impact of Facility(?g/m3)Background Value2(?g/m3)Total Impact w/ Background(?g/m3)CO1-hour40,0003513,6644,015CO8-hour10,0003042,5192,823NOxannual1004.62731.6SO23-hour1,3006139100SO224-hour365323466SO2annual804.76.511Ambient Air Quality Impact EvaluationPermit #AOP-08-015 – September 15, 2008PollutantAveraging time of PSD IncrementPSD Increment Available(?g/m3)Modeled Impact of Facility(?g/m3)NOxannual6.254.6SO23-hour38461SO224-hour6832SO2annual54.71 The National Ambient Air Quality Standards are presented in Subchapter III - Ambient Air Quality Standards - of the Vermont Air Pollution Control Regulations.2 Background values are provided by the Agency and are based on the maximum actual monitored values from the Agency’s ambient monitoring network across the State over the past three (3) years.3 Prevention of Significant Deterioration Increments are presented in Table 2 of the Vermont Air Pollution Control Regulations. All areas in Vermont with the exception of the Lye Brook Wilderness Area are classified as Class II. In addition, pursuant to §5-502(5) of the Regulations major modifications are only allowed a maximum of 25% of the total remaining annual increments and 75% of the total remaining short term increments. No nearby sources were assumed to have consumed increment therefore the full increment (factored by 25%-75%) is available. 7.0HAZARDOUS AIR CONTAMINANTSPursuant to §5-261 of the Regulations, any stationary source subject to the rule with current or proposed actual emissions of a hazardous air contaminant (HAC) equal to or greater than the respective Action Level (found in Appendix C of the Regulations) shall be subject to the Regulation and shall achieve the Hazardous Most Stringent Emission Rate (HMSER) for the respective HAC. HMSER is defined as a rate of emissions which the Secretary, on a case-by-case basis, determines is achievable for a stationary source based on the lowest emission rate achieved in practice by such a category of source and considering economic impact and cost. HMSER may be achieved through application of pollution control equipment, production processes or techniques, equipment design, work practices, chemical substitution, or innovative pollution control techniques. The Facility is anticipated to have emissions of several hazardous air contaminants (HACs). Some HACS are present as NMOCs in the LFG, and these HACS are emitted as fugitive emission from the Landfill Operation. Some fraction of these NMOCs are also emitted from the control devices (flare and CAT 3520C engine) at the Facility, as these control devices are assumed to destroy approximately 98 percent of the NMOCs contained in the LFG. The estimated HACs emitted from the operation of the Facility, and those HACs that were identified as having estimated emissions in excess of their respective Action Levels are presented in Table 7-1.The CAT 3520C engine also creates other HACs, (primarily formaldehyde) as a combustion byproduct. The emissions of formaldehyde were estimated based on a formaldehyde emission factor of 0.177 g/bhp-hr as discussed in Section 3.2.2, and emissions testing will be performed at the LFGTE Operation to provide a site-specific emission factor for VOC emissions from the CAT 3520C engine. This emission factor will be based on a speciated analysis of the VOCs contained in the exhaust from the CAT 3520C engine. Another combustion byproduct is silicon dioxide (SiO2) that is emitted from the engine and flare from the combustion of siloxanes contained in the LFG. It is unclear at this time if the uncontrolled emissions of SiO2 will exceed the Action Level, as the crystallographic structure and particle size of SiO2 particles affects their toxicity. If the SiO2 particles are crystalline silica (CAS # 14808-60-7) or fused silica (CAS # 60676-86-0), then estimated SiO2 emissions likely will exceed the ALs for these forms of SiO2, which are 0.010 lb/8-hr and 0.0017 lb-8 hr respectively. If the SiO2 particles are amorphous silica (CAS # 61790-53-2), it is likely that SiO2 emissions will remain below the AL of 2.0 lb/8 hr. Given the uncertainty regarding what form(s) of SiO2 may be emitted from the combustion of siloxanes, the Agency has determined limiting total PM emissions is an appropriate HMSER for silicon dioxide emissions in general. Accordingly, the Agency has determined that HMSER for all forms of silicon dioxide is a not to exceed 5.7 tons per year limit on total PM emissions from the Facility. It is Agency’s understanding that most siloxanes are emitted during the early portion of the methanogenic cycle in landfills, and emissions of siloxanes will decrease relatively quickly after landfill closure. Siloxane removal equipment at the LFGTE Operation at the Coventry Municipal Solid Waste Facility went on-line in December of 2016, and there currently is insufficient information to assess the long-term performance of this technology. Accordingly, the Agency has not further evaluated siloxane removal requirements at this Facility. Table 7-1 HAC Emissions from Facility OperationParameterTotal Emissions from Facility OperationTotal Emissions (Fugitive+ Flare + Engine)VT HAC Action Level (lbs/8-hr)Percentage of VT HAC Action LevelVT HAC Action Level Exceeded?(lb/hr)(lb/8-hr)(ton/yr)NMOC (Flare / Fugitive)2.71Not Applicable11.85VOC (Flare / Fugitive)1.068.44CAS - No.VOC (Y/N)HAP (Y/N)HAC (Y/N)Non-Methane Organic Compounds(NMOCs) 71-55-6NYY1,1,1-Trichloroethane0.0006160.0049280.000.005294.8%No79-34-5YYY1,1,2,2-Tetrachloroethane0.0000620.0004940.000.001532.9%No79-00-5YYY1,1,2-Trichloroethane0.0000120.0000980.000.00521.9%No75-34-3YYY1,1-Dichloroethane0.0008280.0066210.004.20.2%No75-35-4YYY1,1-Dichloroethene (Vinylidene Chloride) (1,1-Dichloroethylene)0.0000360.0002850.001.70.0%No120-82-1YYN1,2,4-Trichlorobenzene0.0000420.0003330.00----No95-63-6YNN1,2,4-Trimethylbenzene0.0033100.0264840.01----No106-93-4YYY1,2-Dibromoethane (Ethylene dibromide)0.0000350.0002760.000.0003774.7%No76-14-2NNY1,2-Dichloro-1,1,2,2-Tetrafluoroethane (Freon 114) (Dichlorotetrafluoroethane)0.0002940.0023560.0034540.0%No95-50-1YNY1,2-Dichlorobenzene (o-dichlorobenzene)0.0000100.0000810.0016.60.0%No107-06-2YYY1,2-Dichloroethane (Ethylene Dichloride)0.0000410.0003270.000.003210.2%No156-60-5YNY1,2-Dichloroethene (Trans)0.0005210.0041690.001.60.3%No78-87-5YYY1,2-Dichloropropane (Propylene Dichloride)0.0000520.0004150.000.00429.9%No106-46-7YYN1,4-Dichlorobenzene (p-dichlorobenzene)0.0004020.0032150.00----No71-23-8YNY1-Propanol0.0018290.0146350.0118.40.1%No540-84-1YYN2,2,4-Trimethylpentane0.0018810.0150510.01----No110-75-8YNY2-Chloroethoxyethene (2-Chloroethyl vinyl ether)0.0000440.0003520.001.90.0%No67-63-0YNY2-Propanol (Isopropyl Alcohol)0.0043430.0347430.021840.0%No107-05-1YYY3-Chloroprene (Allyl chloride)0.0000210.0001690.000.0082.1%No108-10-1YYY4-Methyl-2-Pentanone (Methyl isobutyl ketone)0.0015210.0121670.012490.0%No67-64-1NNYAcetone0.0087530.0700200.0426.10.3%No107-13-1YYYAcrylonitrile0.0000440.0003510.000.001229.3%No126-99-8YYYb-Chloroprene0.0000350.0002770.000.060.5%No71-43-2YYYBenzene0.0029770.0238150.010.011216.5%Yes75-27-4YNYBromodichloromethane0.0000600.0004820.000.004610.5%No74-83-9YYYBromomethane (Methyl bromide)0.0000220.0001740.000.40.0%No75-15-0YYYCarbon disulfide0.0006750.0054010.0054.50.0%No56-23-5YYYCarbon tetrachloride0.0000570.0004520.000.00558.2%No463-58-1YYNCarbonyl sulfide0.0000220.0001770.00----No108-90-7YYYChlorobenzene0.0001760.0014070.000.20.7%No75-00-3YYNChloroethene (Ethyl Chloride)0.0005540.0044350.00----No67-66-3YYYChloroform0.0000580.0004610.000.003612.8%No74-87-3YYYChloromethane (Methyl Chloride)0.0000720.0005750.007.50.0%NoCAS - No.VOC (Y/N)HAP (Y/N)HAC (Y/N)Non-Methane Organic Compounds(NMOCs) CAS - No.VOC (Y/N)HAP (Y/N)HAC (Y/N)Non-Methane Organic Compounds(NMOCs) 98-82-8YYYCumene0.0004140.0033130.0033.20.0%No110-82-7YNYCyclohexane0.0009860.0078900.006.80.1%No124-18-5YNYDecane0.0244970.1959790.111.910.3%No124-48-1YNYDibromochloromethane0.0000290.0002300.000.00356.6%No75-71-8NNYDichlorodifluoromethane0.0047770.0382190.0216.60.2%No75-09-2NYYDichloromethane (Methylene Chloride)0.0011900.0095220.010.175.6%No64-17-5YNYEthanol (Ethyl Alcohol)0.0068860.0550880.0337.20.1%No141-78-6YNYEthyl Acetate0.0020990.0167920.01950.0%No75-08-1YNYEthyl mercaptan (Ethanethiol)0.0000230.0001830.000.0990.2%No100-41-4YYYEthylbenzene0.0054630.0437020.028.30.5%No75-69-4NNYFluorotrichloromethane (Freon-11) (Trichlorofluoromethane)0.0037210.0297670.0246.60.1%No50-00-0YYYFormaldehyde0.8713586.9708643.820.0065107244.1%Yes76-13-1NNYFreon 113 (1,1,2-Trichloro-1,2,2-trifluoroethane)0.0000990.0007920.0024900.0%No142-82-5YNYHeptane0.0086320.0690550.043640.0%No110-54-3YYYHexane0.0061080.0488600.035810.0%No7783-06-4NNYHydrogen sulfide0.2740132.1921071.200.082740.1%Yes7439-97-6NYYMercury0.0000110.0000910.000.020.5%No79-20-9YNYMethyl Acetate0.0007610.0060860.009.70.1%No78-93-3YNYMethyl ethyl ketone0.0175680.1405400.084150.0%No78-92-2YNYs-Butyl Alcohol/2-Butanol0.0025950.0207590.014.80.4%No100-42-5YYYStyrene0.0000910.0007270.008.30.0%No75-65-0YNYtert-Butanol (2-Methyl-2-Propanol) (t-Butyl alcohol)0.0001940.0015530.0012.60.0%No127-18-4NYYTetrachloroethylene0.0012880.0103010.010.01568.7%No109-99-9YNYTetrahydrofuran0.0094090.0752730.042.92.6%No108-88-3YYYToluene0.0190500.1524000.0824.90.6%No79-01-6YYYTrichloroethylene (Trichloroethene)0.0006550.0052400.000.0413.1%No75-01-4YYYVinyl chloride0.0010050.0080400.000.009188.4%No108-38-3/106-42-3 / 95-47-6YYYXylenes0.0245340.1962700.118.32.4%NoTotal Quantified NMOCs1.3210.535.77Total Quantified VOCs1.028.184.48Total Quantified HAPs0.947.534.12Total Quantified HACs1.3010.425.70As LFG contains a variety of NMOCs which may or may not have been quantified or identified in previous sampling efforts, it is possible that other NMOCs may be present which exceed their respective AL. However, the LFG collection and control requirement that has been implemented for the identified HACs would be anticipated to be equally effective for any unidentified HACs contained in the LFG. The Agency has determined that HMSER for all compounds present as NMOCs in LFG shall continue to be the requirement to achieve the minimum 98% destruction efficiency of the NMOCs in the LFG as required by the prior HMSER and the federal regulations or alternatively demonstrate that the outlet concentrations of NMOCs from the control devices are less than 20 ppmvd measured as hexane. In addition, the Landfill Operation must also comply with various requirements for the collection of LFG to ensure as much gas is collected as is technically feasible and for monitoring of the gas collection and control system operations. Formaldehyde emissions from internal combustion engines are typically minimized by following the manufacturer’s recommendations for operating and maintaining the engines so that they operate at design combustion efficiency. Although the formaldehyde emissions from the CAT 3520C engine at the LFGTE Operation exceed the AL, the location and the emission characteristics of this engine are such that the dispersion of formaldehyde emissions from the stack likely will result in emissions that are less than the Hazardous Ambient Air Standard (HAAS) for receptors that are near the Facility. Factors considered in this review include the following. The nearest receptors to the Facility are approximately 140 meters from the Facility.The proposed stack height of 20 feet, exhaust temperatures of approximately 800 degrees Fahrenheit, and an exit velocity for the engine exhaust of approximately 150 feet per second all contribute to enhancing dispersion of formaldehyde.Formaldehyde is a ubiquitous compound that is also found in the emissions from virgin fuel fired internal combustion engines. The EPA has determined that carbon monoxide (CO) can be used as an appropriate surrogate for formaldehyde, as is generally described in 40 CFR Part 63, Subpart ZZZZ. Accordingly, the Agency has determined that HMSER for formaldehyde emissions from the CAT 3520C LE engine will be the same as the MSER for CO, which incorporates the effects of siloxane combustion and deposition within the combustion chambers of the engines. The HMSER for formaldehyde for the CAT 3520C LE engine will be as follows: 3.5 g/bhp-hr and 17.3 lb/hr (each) applies at all times3.1 g/bhp-hr and 15.3 lb/hr (each) must be demonstrated annually. 2.75 g/bhp-hr and 13.5 lbs/hour (each) must be demonstrated every 6 yearsThere is some uncertainty regarding what form of SiO2 is emitted from the combustion devices at the Facility. Accordingly, based on these considerations, the HMSER for SiO2 from all combustion devices at the Facility will be a restriction on PM emissions from the Facility, limiting PM emissions so that they do not exceed 5.7 tons per year. 8.0PERMIT CONDITION DISCUSSIONCondition (23) of #AOP-12-024 / Condition (10) of #AOP-16-008These Conditions were developed to provide an enforceable restriction on SO2 emissions, such that these emissions are less than the 17.6 ton/year SO2 emission limit proposed by the Permittee. This Condition requires monthly measurement of H2S in the LFG collected from the Landfill and collection of information regarding total LFG volumes delivered in that month to the combustion devices. The formula in this Condition is based on the assumption that H2S concentrations will reflect the amount of sulfur contained in LFG, and that 100 percent of the H2S is converted to SO2 during combustion. The conversion factor for converting H2S concentrations and LFG flow to mass of SO2 was derived as follows:lb SO2/ ppmv H2S -scf LFG = [ppmv H2S]*[1 mole H2S /ppmv H2S * 106 lbmol LFG] * [lbmol SO2/lbmol H2S]*[64.07 lb SO2/lbmol] * [1 lbmol LFG/378.25 scf LFG]lb SO2/ ppmv H2S -scf LFG = 1.694E-7 lb SO2/ppmv H2S -scf LFGThe SO2 emissions generated by the combustion of LFG will be calculated each month, and the monthly emissions will be summed with the total of the emissions from the previous 11 months to verify that the rolling 12-month total of SO2 emissions does not equal or exceed 17.6 tons per rolling twelve-month period. Condition (24) of #AOP-12-024 / Condition (11) of #AOP-16-008These Conditions were developed to provide an enforceable restriction for PM emissions from the Facility. The HMSER for SiO2 emissions included a limitation that Facility PM emissions not exceed 5.7 tons per rolling 12-month period. The formulae in this condition are based on the following assumptions:PM emissions from the CAT 3520C engine will consist of estimated emissions based on an emission factor of 0.2 g/bhp-hr and the actual operating hours from the engine OR an emission factor based on PM testing for the engine performed under Condition (21) of #AOP-16-008. PM emissions from the landfill flare(s) will be the sum of the PM emissions estimated using the AP-42 PM emission factor for landfill flares and the emissions of SIO2 based on siloxane combustion. The total amount of PM emitted from the Facility will be calculated each month, and the monthly emissions will be summed with the total emissions from the previous 11 months to insure that the rolling 12-month total of PM emissions does not equal or exceed 5.7 tons per rolling twelve-month period. Monthly PM emissions shall be calculated in accordance with the following formulae: Equation 1: PM total = PM LFG flares + PM engine combustion Equation 2: PM LFG flares = ( [LFG month flare]*[LFG Heat Value]*[Flare Emission Factor] )*[1 ton/2,000 lb]) + (([LFG month flares]*[Si Concentration flares]*[1 cubic meter/35.31cubic feet]*[1 lb/453,592 mg]*[Molecular weight of SiO2 / Molecular weight of Si]*[1 ton/2,000 lb]Where: LFG month flares = Total collected LFG flow in scf delivered to the flare(s) at the Facility in that monthLFG Heat Value = Heat Value of LFG in MMBtu/scf. A default value of 5.0E-4 MMBtu/scf may be used or a site specific value approved by the Agency.Flare Emission Factor = 1.7E-2 lb/MMBtuSi Concentration flares = Si concentration in LFG to flare(s) in mg Si / cubic meterMolecular weight of Si = 28.09Molecular weight of SiO2 = 60.08Equation 3: PM engine combustion = [Engine Emission Factor] *[1 lb/453.592 g]*[Hours of operation for CAT 3520C engines]*[CAT 3520C engine rating]* [Capacity Factor] * [1 ton/2,000 lb]) Where:Engine Emission Factor = 0.20 g/bhp-hr OR emission factor in g/bhp-hr obtained from stack testing required by Condition (21) of #AOP-16-008 at the Agency’s discretion.Hours of operation for CAT 3520C engine = Total number of hours of operation for the CAT 3520C engine in that month. CAT 3520C engine rating = 2,233 bhp or a site specific value approved by the Agency. Capacity Factor = Measured electrical output in MW of the CAT 3520C engine at the LFGTE Operation in that month / Electrical Output theoreticalElectrical Output theoretical = Electrical output in MW of the CAT 3520C engine at the LFGTE Operation in that month assuming it is operated at 100 percent output for the hours operated. Compliance with this limit shall be documented through measuring and recording:Monthly LFG flow to the CAT 3520C engine in standard cubic feet (scf) Monthly LFG flow to each of the flare(s) in standard cubic feet (scf)Silicon (Si) concentrations in untreated LFG in units of milligrams of Si per cubic meter of LFG measured annually. Monthly hours of operation for the CAT 3520C engine at the LFGTE Operation recorded to the nearest tenth (0.1) hour. Concentrations of Si shall be measured annually using sample collection and chemical analytical methods approved by the AgencyCondition (25) of #AOP-12-024 / Condition (12) of #AOP-16-008These Conditions were developed to provide an enforceable restriction for the 25 ton per year VOC emission limit established for the Facility. VOCs are emitted by several sources at the Facility, including fugitive emissions from the Landfill Operation, VOCs contained in collected LFG that are not destroyed by the flare and/or engine, and VOCs created as a result of incomplete combustion in the engine. It has been assumed that the cover and gas collection system at the Landfill has a 90 percent capture efficiency. Thus, the total amount of captured LFG divided by 0.90 will equal the estimated total LFG generation from the Landfill, and 10 percent of the total LFG generation will be emitted as fugitive LFG. Based on the time frame of landfill operation and an understanding of historical waste acceptance, it was assumed that VOC concentrations in LFG were 464 ppmv as hexane (39% of an estimated NMOC concentration of 1,190 ppm), or 1.03E-04 lb VOC/scf LFG. Accordingly, fugitive VOC emissions will be based on this VOC concentration, and the measured volume of collected LFG multiplied by (0.10/0.90) Combustion of LFG in the flares at the Facility is assumed to result in 98 percent destruction of any VOC compounds contained in the LFG. Accordingly, emissions of VOCs from the flare will be based on the assumption that 2 percent of the 1.03E-04 lb VOC/scf LFG is emitted from LFG combustion in the flares. Combustion of LFG in the CAT 3520C LE engine at the LFGTE Operation is more complex, in that VOCs contained in LFG are destroyed by combustion, but VOCs (notably formaldehyde) are also created from incomplete combustion of methane in the LFG. To estimate total VOC emissions from the engine, the Agency has determined that combustion emissions of VOCs from the engine, exclusive of formaldehyde may be estimated as 39 percent of the most recent measured value for NMOC emissions from stack testing of the CAT 3520C engine at the LFGTE Operation. To account for formaldehyde emissions, the formaldehyde emission factor of 5.28E-02 lb/MMBtu of heat input was obtained from AP-42, Chapter 3: Stationary Internal Combustion Sources, Section 3.2, Natural Gas-fired Reciprocating Engines, Table 3.2-2 Uncontrolled Emission Factors for 4-Stroke Lean-Burn Engines, (Supplement F, August 2000). Assuming a fuel heat value of 500 Btu/scf, and an LFG supply rate to each engine of 550 scf of LFG results in an estimated emission factor for formaldehyde of 0.177 g/bhp-hr. Stack testing will be required to assess if this estimate of formaldehyde emissions is appropriate. The emissions factor for compliance will be adjusted, at the discretion of the Agency, to either the factor estimated as described above, or to the stack test result obtained from emissions testing required as part of #AOP-16-008. Total Facility emissions of VOCs will be the sum of fugitive VOC emissions, VOC emissions from the flares, and VOC emissions from the CAT 3520C engine. The equations used to calculate total VOC emissions are as follows: The quantity of VOC emissions from the Facility shall be determined on a monthly basis in accordance with the following formulae:Equation 1: VOC total = VOC fugitive + VOC flares + VOC engine combustionEquation 2: LFG fugitive = [LFG month / Percent Capture Efficiency]*[1 - Percent Capture Efficiency]Equation 3: VOC fugitive = [LFG fugitive]*[ 1.04E-4 lb VOC/scf LFG]*[1 ton/2,000 pounds]Where:LFG month = The total collected LFG flow in scf delivered to all combustion devices at the Facility in that monthLFG fugitive = The total fugitive LFG emitted from the Facility in that monthPercent Capture Efficiency = 0.90 Percent Fugitive Emissions = [1 - Percent Capture Efficiency]Percent capture efficiency is expressed as a decimal equivalent (i.e. 90% = 0.90)Equation 4: VOC flares = [LFG flow in scf delivered to flares]*[ 1.04E-4 lb VOC/scf LFG]*[1-Destruction Efficiency]*[1 ton/2,000 pounds]Where:Destruction Efficiency = 0.98 Percent destruction efficiency expressed as a decimal equivalent (i.e. 98% = 0.98)Equation 5: VOC engine combustion = [Total Engine Operating Hours*Engine Horsepower] * [Capacity Factor] * [VOC Emission Factor] * [1 lb/453.59 g] *[1 ton/2,000 pounds]Where:Total Engine Operating Hours = The total operating hours for the CAT 3520C engine at the LFGTE Operation in that month.Engine Horsepower = Rated output of the CAT 3520C engine, or 2,233 bhpCapacity Factor = Measured electrical output in MW of the CAT 3520C engine at the LFGTE Operation in that month / Electrical Output theoreticalElectrical Output theoretical = Electrical output in MW of the CAT 3520C engine at the LFGTE Operation in that month assuming they are operated at 100 percent output for the hours operated. VOC Emission Factor = 39 percent of the measured NMOC emission factor from the most recent yearly engine emissions testing in accordance with Condition (9) of #AOP-16-008 in grams per brake horsepower-hour plus the AP-42 formaldehyde emission factor for natural-gas fired engines of 0.177 grams per bhp-hr. OR, at the Agency’s discretion,VOC Emission Factor = Measured emission factor obtained from stack testing performed under Condition (20) of #AOP-16-008. The total amount of VOCs emitted from the Facility will be calculated each month, and the monthly emissions will be summed with the total emissions from the previous 11 months to insure that the rolling 12-month total of VOC emissions does not equal or exceed 25 tons per rolling twelve-month period. Condition (20) of #AOP-16-008This Condition was developed to obtain a site-specific value for the VOC emissions from the CAT 3520C LE engine. There is little available information describing VOC emission factors for internal combustion engines fired with LFG, and given the potential quantity of VOCs generated by the CAT 3520 engine at the Facility, the Agency has determined that establishing a site-specific emission factor for formaldehyde was necessary to accurately estimate Facility VOC emissions. Note that the permit assumes an emission factor in the equation but this is not a formaldehyde emission limit. Rather the VOC emission limit is 25 tons per rolling twelve month period. Condition (21) of #AOP-16-008This Condition was developed to obtain a site-specific value for PM emissions from the CAT 3520C LE engine, and to verify compliance with the emissions limitations of #AOP-16-008. There do not appear to be any previous emissions testing for PM from this engine, so it is unclear if this engine is in compliance with the PM emissions limitations originally imposed in the Application for #AOP-08-015 and currently imposed in #AOP-16-008. ................
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