OREGON DEPARTMENT OF ENVIRONMENTAL … gas (LFG) collection system. The landfill gas is either sent to enclosed flares or to landfill gas The landfill gas is either sent to enclosed

Columbia Ridge Landfill & Recycling Center Review Report/Permit No.: 11-0001-TV-01 Application Number: 28669 Page 1 of 33

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT

REVIEW REPORT Eastern Region

475 NE Bellevue Dr., Suite 110 Bend, OR 97701

Source Information:

SIC 4953, 4911

NAICS 562212, 221117

Source Categories (Part and code) B-27, C-4

Compliance and Emissions Monitoring Requirements:

Unassigned emissions

Emission credits

Compliance schedule

Source test [date(s)] within 1 yr of startup

COMS

CEMS

PEMS

Ambient monitoring

Reporting Requirements

Annual report (due date) 2/15

Emission fee report (due date) 2/15

SACC (due date) 2/15, 7/30

Quarterly report (due dates) 45 days after quarter

Monthly report (due dates)

Excess emissions report X

Other reports (type)

Air Programs

NSPS (list subparts) A, WWW, JJJ

NESHAP (list subparts) A, AAAA, ZZZZ

CAM

Regional Haze (RH)

Synthetic Minor (SM) X (HCl)

Part 68 Risk Management Yes

CFC

RACT

TACT

Title V X

ACDP (SIP) X

Major HAP source

Federal major source X

NSR

PSD X

Acid Rain


TABLE OF CONTENTS LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT ............................................................................. 3 INTRODUCTION ......................................................................................................................................................... 4 PERMITTEE IDENTIFICATION ................................................................................................................................ 4 FACILITY DESCRIPTION .......................................................................................................................................... 5 EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION ................................................... 5 EMISSION LIMITS AND STANDARDS, TESTING, MONITORING AND RECORDKEEPING .......................... 8 PLANT SITE EMISSION LIMITS ............................................................................................................................. 12 HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 14 GENERAL BACKGROUND INFORMATION ......................................................................................................... 15 COMPLIANCE HISTORY ......................................................................................................................................... 16 SOURCE TEST RESULTS ......................................................................................................................................... 16 PUBLIC NOTICE ....................................................................................................................................................... 21 ATTACHMENT A: RESPONSE TO COMMENTS ................................................................................................. 22 ATTACHMENT B: EMISSIONS DETAIL SHEETS ............................................................................................... 24


LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT AQMA Air Quality Management Area ASTM American Society of Testing and

Materials BDT Bone Dry Ton CEMS Continuous Emissions Monitoring

System CFR Code of Federal Regulations CH4 Methane (greenhouse gas) CMS Continuous Monitoring System CO Carbon Monoxide CO2e Carbon Dioxide Equivalent COMS Continuous Opacity Monitoring

System DEQ Oregon Department of

Environmental Quality dscf dry standard cubic feet EF Emission Factor EPA United States Environmental

Protection Agency EU Emissions Unit FCAA Federal Clean Air Act GHG Greenhouse Gas gr/dscf grains per dry standard cubic feet HAP Hazardous Air Pollutant ID Identification Code I&M Inspection and Maintenance LFG Landfill Gas MB Material Balance Mlb 1000 Pounds

MM Million N2O Nitrous Oxide (greenhouse gas) NA Not Applicable NESHAP National Emission Standard for

Hazardous Air Pollutants NOx Oxides of Nitrogen NSPS New Source Performance Standard NSR New Source Review O2 Oxygen OAR Oregon Administrative Rules ORS Oregon Revised Statutes O&M Operation and Maintenance Pb Lead PCD Pollution Control Device PEMS Predictive Emissions Monitoring

System PM Particulate Matter PM10 Particulate Matter less than 10

microns in size PM2.5 Particulate Matter less than 2.5

microns in size PSD Prevention of Significant

Deterioration PSEL Plant Site Emission Limit SO2 Sulfur Dioxide ST Source Test VE Visible Emissions VMT Vehicle Miles Traveled VOC Volatile Organic Compound


INTRODUCTION 1. This is a renewal of an existing Title V Operating Permit issued to Waste Management Disposal Services

of Oregon, Inc. on 6/18/2012 and scheduled to expire on 6/1/2017. A timely renewal application was received on 5/27/16. The current permit will remain valid until DEQ takes action on this renewal.

2. In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual

basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the same as the legal basis. However, when the regulation is not specific and only provides general requirements, this Review Report is used to provide a more thorough explanation of the factual basis for the draft permit conditions.

3. The following changes have been made to the permit since the last renewal.

Date Permit Revision or Notification Brief Explanation 5/12/14 Notice of Construction Expansion of landfill gas collection and control system

10/13/15 Notice of Construction Expansion of landfill gas collection and control system

7/8/16 Significant Permit Modification Incorporation of additional landfill gas engines into Title V from PSD permit

4. The following changes have been made during this permit renewal:

New Permit Condition Number

Old Permit Condition Number

Description of Change Reason for Change

5.a.vii -- Added condition for control of

fugitives by removal of material from paved roads that may become airborne

Reflects rule language in OAR 340-208-0210(1)(g).

77 77 Modified PSEL for several pollutants

Source test information was used to modify the emission factors. The

PSEL for SO2, NOx, CO, NMOC and GHG decreased. The PSEL for VOC increased due to the increase in mass

of waste that is producing LFG.

77 77 Added a PSEL for HCl

The potential to emit HCl is 9.4 tons/yr which is close to major HAP

source threshold. The PSEL is set at 9 tons/yr as a synthetic minor limit.

Table 9 Table 9 Updated emission factors for FLR-1

and LFG ENG due to results of recent source test data

Site-specific emission factors provide a more accurate emission estimate.

86-88 87-89 Moved general recordkeeping

requirements to a location prior to specific recordkeeping requirements

Format change.

PERMITTEE IDENTIFICATION 5. Waste Management Disposal Services of Oregon, Inc. (Columbia Ridge Landfill and Recycling Center)

operates a municipal solid waste landfill located approximately 10 miles south of the City of Arlington, Oregon. The process includes landfilling of primarily municipal solid waste. The landfill maintains a landfill gas (LFG) collection system. The landfill gas is either sent to enclosed flares or to landfill gas


engines to generate electricity. The landfill was originally sited in 1988 while the LFG management system was installed in 1998. The landfill gas collection system has expanded as the landfill continues to accept waste. The facility’s design or permitted capacity is approximately 354,275,000 cubic yards of solid waste based on the plans approved under the permittee’s solid waste permit.

FACILITY DESCRIPTION 6. The site consists of 2,036 acres, of which approximately 700 acres will be developed into an active landfill.

The landfill is divided into modules which allow waste to be added in an organized way that maximizes capacity. Earth is moved and a liner system installed to prepare each module to receive waste. Waste is received by train and by truck and transported to an active module. Cover soil is placed on the waste as it is accumulated such that only a small portion of waste in the module is exposed at any time. This area is the active face where waste is placed and compacted. Keeping the non-active portions of the module covered reduces odor, windblown litter, and fugitive emissions. Sweeping of the paved areas and application of water on paved and unpaved areas reduces fugitive particulate emissions due to vehicle traffic.

The landfill gas, which contains approximately 51% methane, is collected by a system of vertical and horizontal collection wells and by connections to the leachate collection risers. The landfill gas can be combusted in several existing internal combustion engines to generate electricity, or destroyed in several flares (2 enclosed flares or a candlestick flare). The facility has installed twelve engines and plans to install four additional engines to generate electricity.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION 7. The emissions units at this facility are the following:

UPR: Fugitive particulate emissions from vehicular traffic on unpaved roads. Emissions are controlled by water application, chemical dust suppression, and/or gravel application, as necessary.

UPR-1 Columbia Ridge-Chem Waste lower interconnecting road 0.3 miles UPR-2 Main haul road 0.2 miles UPR-3 Transfer station rail yard and 10-day staging area 0.7 miles

PRD: Fugitive particulate emission from vehicular traffic on paved roads. Emissions are controlled by

water application and road sweeping, as necessary.

PRD-1 Main haul road 1.7 miles PRD-2 Transfer station rail yard 0.7 miles PRD-3 Transfer station rail gondola unloading facility access road 0.7 miles PRD-4 Columbia Ridge-Chem Waste lower interconnecting road 0.5 miles

LFG: Fugitive emissions from the landfill area due to anaerobic decomposition of waste in the landfill.

Although a collection system is in place, it is estimated that only 85% of the generated landfill gas is collected. The remaining 15% is emitted.

FLR: Two enclosed flares (FLR-1, FLR-2, both rated at 4,000 scfm, 132 MMBtu/hr) and smaller utility

flare (FLR-3, rated at 1,350 scfm, 40.5 MMBtu/hr) burn landfill gas collected from the landfill. Generally, the majority of landfill gas collected is burned in the landfill gas engines to generate electricity. Gas generated beyond the capacity of the landfill gas engines to burn is sent to the enclosed flares. Gas is also routed to the enclosed flares during maintenance to the engines. The utility flare is infrequently used as a backup during maintenance of the other flares.


LFG ENG: Eight Caterpillar G3516 gas engine generator sets (LFG ENG-01 through -08) are lean burn

engines that are rated at 800 kW (10.49 MMBtu/hr, 333 scfm) each and were manufactured prior to 1/1/08 and installed 7/1/09. Each engine vents to a stack that is 30 feet tall and 16 inches in diameter. The engines have no add-on control devices.

Four Caterpillar 3520C gas engine generator sets (LFG ENG-09 through -12) also burn landfill gas and are each rated at 1,600 kW (17.44 MMBtu/hr, 547 scfm) and were installed in 2013. Each engine vents to a stack that is 33 feet-2 inches tall and 16 inches in diameter. These engines also have no add-on control devices. This permit allows construction of four additional Caterpillar 3520C gas engine generator sets (LFG ENG-13 through -16) under the current PSD permit. These engines will also be rated at 1,600 kW (17.44 MMBtu/hr, 547 scfm) and construction will commence when the landfill generates sufficient LFG. Each engine will vent to a stack that is 33 feet-2 inches tall and 16 inches in diameter. The engines will have no add-on control devices.

ENG: This group contains 42 internal combustion engines that are used in various parts of the facility to power the trailer tippers, portable light stands, leachate recirculation pumps, storm water pumps, and equipment maintenance. The engines are either diesel or gasoline powered and range in size from 11 to 123 hp. Some of these engines are spare or are used intermittently.

Engines Fuel Size

15 light stands Diesel 15 hp Portable pump engine Diesel 48 hp

Trailer tipper 01 Diesel 125 hp Trailer tipper 02 Diesel 125 hp Trailer tipper 03 Diesel 150 hp Trailer tipper 04 Diesel 150 hp Trailer tipper 05 Diesel 115 hp

Compressor Diesel 70 hp Portable pump engine Gasoline 15 hp

Miscellaneous Gasoline 1 hp Miscellaneous Gasoline 5 hp

PCS: Petroleum contaminated soil is sometimes used for daily cover and is a source of volatile organic

emissions. MH: Material handling includes the deposition and removal of soil from stockpiles to modules in the

landfill. Piles: Soil stockpiles used to store daily cover. AI: Aggregate insignificant activities.

8. Categorically insignificant activities include the following:

• Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

• Evaporative and tail pipe emissions from on-site motor vehicle operation


• Distillate oil, kerosene and gasoline fuel burning equipment rated at less than or equal to 0.4 million Btu/hr

• Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu/hr • Office activities • Food service activities • Janitorial activities • Personal care activities • Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance • On-site laundry activities • Instrument calibration • Maintenance and repair shop • Automotive repair shops or storage garages • Air cooling or ventilating equipment not designed to remove air contaminants generated by or released

from associated equipment • Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated

under Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment associated with such systems

• Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical analysis, including associated vacuum producing devices but excluding research and development facilities

• Temporary construction activities • Warehouse activities • Accidental fires • Air vents from air compressors • Air purification systems • Continuous emissions monitoring vent lines • Demineralized water tanks • Electrical charging stations • Fire brigade training • Instrument air dryers and distribution • Fire suppression • Blueprint making • Routine maintenance, repair and replacement such as anticipated activities most often associated with

and performed during regularly scheduled equipment outages to maintain a plant and its equipment in good operating condition, including but not limited to steam cleaning, abrasive use and woodworking

• Electric motors • Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual

fuels, lubricants and hydraulic fluids • On-site storage tanks not subject to any New Source Performance Standards (NSPS), including

underground storage tanks (UST), storing gasoline or diesel used exclusively for fueling of the facility's fleet of vehicles

• Natural gas, propane and liquefied petroleum gas (LPG) storage tanks and transfer equipment • Pressurized tanks containing gaseous compounds • Storm water settling basins • Fire suppression and training • Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those

sources that have processes or activities that contribute to the deposition and entrainment of hazardous air pollutants from surface soils

• Health, safety and emergency response activities


• Emergency generators and pumps used only during loss of primary equipment or utility service due to circumstances beyond the reasonable control of the owner or operator, or to address a power emergency as determined by DEQ

• Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems • Non-contact steam condensate flash tanks • Non-contact steam vents on condensate receivers, deaerators and similar equipment • Boiler blowdown tanks • Industrial cooling towers that do not use chromium-based water treatment chemicals • Combustion source flame safety purging on startup

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING AND RECORDKEEPING 9. Fugitive Emissions – OAR 340-208-0210 is a requirement to take reasonable precautions to minimize

fugitive particulate emissions.

9.a. Testing Requirements: By definition it is not possible to perform source emission tests on fugitive emission sources. Therefore, the permit does not include any testing requirements or compliance test methods.

9.b. Monitoring Requirements: To satisfy the Title V periodic monitoring requirements, the permittee is required to perform a visible emissions survey at specified frequencies that can be gradually reduced based upon previous monitoring results to determine if any visible emissions are leaving the plant site boundaries. If there are visible emissions the permittee must take corrective action to minimize the fugitive emissions. The permittee must maintain records of the surveys and corrective actions, if necessary.

10. Nuisance – OAR 340-208-0300 is a requirement that prohibits nuisance conditions from a source, and

OAR 340-208-0450 is a requirement that prohibits particulate fallout from a source. These requirements are not part of the State Implementation Plan (SIP) so they are enforceable only by the State. Nuisance conditions must be verified by DEQ. In order to determine whether a nuisance condition may exist, the permittee is required to keep a log of any complaints and report them to DEQ. The permittee is also required to respond to the complainant within a reasonable amount of time and conduct an investigation as to whether any operations under their control may have caused a nuisance condition.

11. Sulfur Content of Fuel Oil – OAR 340-228-0110 is a sulfur content limit for distillate fuel.

11.a. Testing Requirement: This is a state requirement that applies to fuel users as well as fuel suppliers, so it should not be possible for the permittee to purchase any fuel containing more sulfur than specified by the rule. Therefore, the permittee is not required to test the fuel, but they are required to obtain a certificate from the supplier stating that the fuel meets the specifications. If they cannot get a certificate, then the permittee would have to analyze a sample of the fuel to show that it meets the specifications.

11.b. Monitoring Requirements: The permittee is required to maintain records of the sulfur content of diesel used at the facility.

12. Since the landfill was constructed after 1970, the facility is subject to a 20% opacity limit as a 6-minute

block average for all non-fugitive sources. [OAR 340-208-0110(4)]

12.a. Testing Requirement: EPA Method 9 is used to measure opacity, when required. 12.b. Monitoring Requirement: Proper maintenance and operation of the engines and flares should

ensure the opacity is within the limits. The permit will require maintenance in accordance with the manufacturer’s recommendation to ensure proper operation of these units.


13. The grain loading standards of OAR 340-226-0210 apply only to the non-fugitive sources at the facility. This includes the flares and engines. The grain loading standards for fuel burning equipment in OAR 340-228-0210 do not apply to this facility because internal combustion engines are excluded from the definition of fuel burning equipment. [OAR 340-200-0020(69)]

13.a. The enclosed flares (FLR-1, FLR-2) and all currently installed LFG engines (LFG ENG-01

through -12) were installed between June 1, 1970 and April 16, 2015 and all compliance source test results on these units have demonstrated particulate emissions less than 0.080 gr/dscf. Therefore, the grain loading limit for these units is 0.10 gr/dscf. [OAR 340-226-0210(2)(b)(A)]

13.b. The non-landfill gas engines (ENG) were installed between June 1, 1970 and April 16, 2015, but have not been tested for particulate emissions. Therefore, the grain loading limit for these units is 0.14 gr/dscf. [OAR 340-226-0210(2)(b)(B)]

13.c. The four new LFG engines will be installed after April 16, 2015 and are subject to a grain loading limit of 0.10 gr/dscf. [OAR 340-226-0210(2)(c)]

13.d. Testing Requirement: All of the enclosed flares and installed LFG engines have been tested to demonstrate compliance with the grain loading limit. The new LFG engines will be tested within one year of startup. No further particulate testing will be required during this permit term.

13.e. Monitoring Requirement: Proper maintenance and operation of the flares and LFG engines should ensure compliance with the limit.

14. Asbestos Handling – Since asbestos is disposed at the landfill, the requirements of OAR 340-248-0280 and

40 CFR Part 61, Subpart M apply. These requirements deal mostly with proper handling and disposal, and associated recordkeeping.

15. 40 CFR Part 68 – Accidental Release Prevention Regulations do not apply to the facility at this time as

there are no substances stored or used at the facility in threshold quantities. However, this regulation may be applicable in the future if the threshold quantities are exceeded.

16. This facility is subject to Subpart A of the New Source Performance Standards (NSPS – 40 CFR Part 60)

since this Subpart is referenced in Subparts WWW.

Summary of NSPS Subpart A General Provision Requirements: Part 60 Citation Requirement Permit Action 60.7(a)(1)&(3) Initial design capacity report This report has been submitted

60.7(a)(4) Notification of physical or operational change to an existing affected facility that may increase emissions

Permit contains condition requiring notification of any physical or operational change that may increase emissions

60.7(a)(5) Notification of the date upon which demonstration of CMS performance commences

CMS are not required or installed at this facility

60.7(a)(6) Notification of the date for conducting opacity observations required by 60.11(e)(1) Not applicable for this source

60.7(a)(7) Notification that COMS data will be used for determining compliance with opacity standards

Not applicable for this source

60.7(b) Maintain records of startup, shutdown and malfunctions

Applicable requirement contained in permit

60.7(c), 60.7(d), and 60.7(e) Excess emissions reporting

CMS used to monitor excess emissions is not required for this facility. Excess emissions are not measured and do not require reporting under this regulation

60.7(f) Maintain CEMS records Not applicable for this source 60.8 Conduct performance tests All initial testing has been completed


Part 60 Citation Requirement Permit Action 60.11 (b) and

60.11(e) Opacity observations in conjunction with performance tests Not applicable for this source

60.11(d) Operate equipment with good air pollution control practices

Applicable requirement contained in permit

60.11(g) Credible evidence Applicable requirement contained in permit

60.12 Circumvention Applicable requirement contained in permit.

60.13 Continuous monitoring system Not applicable for this source

60.18 General control device requirements Not applicable to LFG engines or enclosed flare but is applicable to utility flare

17. This facility is subject to NSPS, Subpart WWW – Standards of Performance for Municipal Solid Waste

Landfills. The facility began receiving waste in 1990 but was modified after 5/30/91. The landfill’s current design capacity is approximately 354,275,000 cubic yards of solid waste, well above the 3.27 million cubic yards (2.5 million cubic meters) level that requires monitoring of non-methane organic compound (NMOC) emissions. The NMOC emissions have been determined to be greater than 50 megagrams per year. The permittee has designed, installed, and currently operates a landfill gas collection and control system in accordance with 40 CFR 60.752(b)(2). The NMOC is reduced by either:

17.a. Routing the collected gas to a treatment system that processes the gas for subsequent use in one of

twelve existing and 4 proposed landfill gas engines or for use off-site; [40 CFR 60.752(b)(2)(iii)(C)]

17.b. Sending the collected gas to one of two enclosed flares. The flares are designed and operated to either reduce NMOC emissions by 98% by weight or reduce the outlet NMOC concentration to less than 20 ppmv, dry basis as hexane at 3% oxygen. [40 CFR 60.752(b)(2)(iii)(B)] or

17.c. Routing the collected gas to an open (utility) flare designed and operated in accordance with 40 CFR 60.18. [40 CFR 60.752(b)(2)(iii)(A)]

18. The LFG collection system must operate in modules where solid waste has been in place for 5 years if the

module is active and 2 years if the module is at final grade. [40 CFR 60. 753(a)] Each wellhead of the LFG collection system must be operated at negative pressure unless the positive pressure is an attempt to address the potential for fire or increased wellhead temperature. [40 CFR 60.753(b)] Each interior wellhead must maintain a gas temperature below 55°C and either a nitrogen level less than 20% or an oxygen level less than 5%, unless approved by DEQ. [40 CFR 60.753(c)] Operating parameters at the wellhead will be measured monthly. [40 CFR 60.756(a)] The collection system must be operated so that the concentration of methane at the surface of the landfill is less than 500 ppm above the background concentration. A monitoring plan has been developed to measure the methane concentration at the surface of the landfill. [40 CFR 60.753(d)] Corrective action will be taken if the pressure, temperature, nitrogen or oxygen content at the wellhead exceeds the limits or the surface methane concentration limit is exceeded. [40 CFR 60.755] The collection and control system is operated such that all collected LFG is ducted to a LFG control system (engines or flares). The collection system will be shut down if the control system is inoperable and all valves in the collection and control system contributing to the venting of LFG to the atmosphere will be closed within 1 hour. [40 CFR 60.753(e)]

19. The test methods in 40 CFR 60.754 for determining NMOC emissions from the landfill and control

efficiency of the flares are included in the permit. 20. The permittee must measure the temperature and LFG flow rate to the enclosed flare. Periodic inspections

will be used to verify the flare bypass valve is closed. [40 CFR 60.756(b)] The permittee must measure the LFG flow rate to the utility flare and ensure a flame is present. [40 CFR 60.756(c)]


21. Subparts IIII and JJJJ – Standards of Performance for Stationary Compression Ignition and Spark Ignition Internal Combustion Engines do not apply to the small diesel and gas engines on-site because construction of these engines commenced prior to 6/12/06. In addition, Subpart JJJJ does not apply to landfill gas engines LFG ENG-1 through -08 because these spark ignition internal combustion engines are lean-burn and were manufactured prior to 01/01/08. [40 CFR 60.4230(a)(4)(ii)] Subpart JJJJ does apply to landfill gas engines LFG ENG-09 through -16.

22. This facility is subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart

A – General Provisions, Subpart AAAA – Municipal Solid Waste Landfills, and Subpart ZZZZ – Stationary Reciprocating Internal Combustion Engines. Since landfill construction began before 11/7/00 the facility is considered an existing source for Subpart AAAA. [40 CFR 63.1940(c)]. The non-landfill gas engines are not stationary and, therefore, not subject to Subpart ZZZZ. Since construction on the landfill gas engines commenced after 6/12/06 the LFG engines are considered new sources for Subpart ZZZZ. [40 CFR 63.6590(a)(2)(iii)] As new engines at an area source for HAP emissions, the facility must meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ (NSPS for Stationary Spark Ignition Internal Combustion Engines). [40 CFR 63.6590(c)] Since 40 CFR 60, Subpart JJJJ is not directly applicable to LFG ENG-01 through -08 EPA has determined that there would be no applicable requirements for these engines due to 40 CFR 63, Subpart ZZZZ. There are applicable requirements for LFG ENG-09 through -016. These conditions will be included in the Title V Permit.

Summary of NESHAP Subpart A – General Provision Requirements (from Subpart AAAA, Table 1):

Part 63 Citation Description Explanation

63.1(a) General applicability The provisions of (a)(10) through (a)(12) are similar to provisions of NSPS, Subpart A

63.4 Prohibited activities and circumvention Similar to provisions from NSPS, Subpart A

63.6(e)(3) Operation and maintenance requirements, startup, shutdown and malfunction plan

Applicable requirements are contained in permit

63.6(f) Compliance with non-opacity emission standards

Similar to NSPS, Subpart A requirement. Applicable requirements are contained in permit

63.10(b)(2)(i) through (v) General recordkeeping requirements Applicable requirements are contained in permit

63.10(d)(5) Periodic startup, shutdown and malfunction reports Applicable requirements are contained in permit

63.12(a) State authority and delegation The Department has not adopted standards more stringent than those specified

63.15 Availability of information and confidentiality Applicable requirements are contained in permit

23. The facility is subject to Subpart AAAA since it has accepted waste after 11/8/87 and is an area source of

HAP that has a design capacity greater than 2.5 million cubic meters and estimated uncontrolled emissions of NMOC greater than 50 Mg/year. [40 CFR 63.1935]

24. Since landfill construction began before 11/7/00 the facility is considered an existing source for Subpart

AAAA. [40 CFR 63.1940(c)]. 25. The facility has installed and is operating a landfill gas collection and control system and has been in

compliance with Subpart AAAA. [40 CFR 63.1945] Inspection will verify future compliance with this subpart. The permittee must continue to comply with this subpart until it is no longer required to apply LFG control as specified in 40 CFR 60.752(b)(2)(v). [40 CFR 63.1950]

26. In order to comply with Subpart AAAA the permittee must comply with the requirements of 40 CFR 60,

Subpart WWW. [40 CFR 63.1955] The testing, monitoring and other requirements in Subpart WWW are sufficient to demonstrate compliance with Subpart AAAA.


27. As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include

categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter (0.10 gr/dscf limit). DEQ does not consider it likely that IEUs could exceed an applicable emissions limit or standard because IEUs are generally equipment or activities that do not have any emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions. Since there are no controls, no visible emissions, and the emissions are less than one ton per year, DEQ does not believe monitoring, recordkeeping or reporting is necessary for assuring compliance with the standards.

28. 40 CFR 64, OAR 340-212-0200 through 340-212-280, Compliance Assurance Monitoring (CAM) does not

apply to this facility. Emission units subject to CAM generally must have an applicable emission limit (except for NSPS and NESHAP standards issued after November 15, 1990), use a control device to achieve compliance with the standard, and have pre-control emissions greater or equal to 100 tons/yr. Fugitive landfill gas emissions are subject to an NSPS (Subpart WWW) and NESHAP (Subpart AAAA) but these regulations were promulgated after November 15, 1990 which makes them exempt from CAM. [OAR 340-212-0200(2)(a)(A)] The landfill gas engines emit more than 100 tons/yr and some (LFG ENG-09 through -16) are subject to the stationary engine NSPS and NESHAP. However, the engines do not have control devices and, hence, are not subject to CAM.

PLANT SITE EMISSION LIMITS 29. Provided below is a summary of the baseline emission rates, netting basis, and plant site emission limits.

Pollutant

Baseline Emission

Rate (tons/yr)

Netting Basis Plant Site Emission Limit (PSEL) Previous

PSEL (tons/yr)

Proposed PSEL (tons/yr)

PSEL Increase (tons/yr)

Previous (tons/yr)

Proposed (tons/yr)

PM 0 106 106 114 114 0 PM10 0 63 63 72 72 0 PM2.5 -- 54 54 63 63 0 CO 0 1099 1099 1136 846 -290 NOx 0 324 324 333 298 -35 SO2 0 218 218 218 47 -171

VOC 0 199 199 172 180 8 NMOC 0 172 172 145 141 -4

H2S/TRS 0 12 12 12 12 0 HCl 0 0 0 9 9 0

GHG (CO2e) 241,300 241,300 241,300 641,100 639,600 -1,500

29.a. The permittee did not operate during the 1977-78 baseline period. Therefore the baseline emission rate for all pollutants except greenhouse gas is zero. In accordance with OAR 340-222-0048(3), baseline emission rates for PM2.5 will not be established. The baseline emission rate for GHG is based on 2010 emissions as established in a previous permit.

29.b. The previous netting basis is equal to the value established in the previous Title V Significant Permit Modification, which included a new netting basis established in the Prevention of Significant Deterioration (PSD) permit.

29.c. The proposed netting basis is equal to the previous netting basis. 29.d. Much of the proposed netting basis is based on the potential to emit of the emission units that were

part of the PSD review. In 2023, (ten years after issuance of the PSD permit) the netting basis will be reduced in accordance with the definition of actual emissions. [OAR 340-222-0051(3)]

29.e. The previous PSEL is the PSEL in the last modification of this permit (7/8/16 Title V


Modification). HCl emissions are included in the PSEL since an increase in HCl emissions could cause this facility to become a major source of Hazardous Air Pollutant (HAP) emissions, which can affect the applicability of some regulations. This is a synthetic minor limitation intended to keep emissions below the major hazardous air pollutant threshold.

29.f. The proposed PSEL is different than the previous PSEL due to use of emission factors based on actual source test results for the flares and the landfill gas engines. Specific emission information is included in the Emission Detail Sheets in Attachment B.

29.g. The PSEL is a federally enforceable limit on the potential to emit. SIGNIFICANT EMISSION RATE 30. The proposed PSEL is greater than the previous netting basis as shown below.

Pollutant SER Requested Increase

Over Previous Netting Basis

Increase Due to Utilizing Capacity that Existed in the Netting

Basis Period

Increase Due to Physical Changes or

Changes in the Method of Operation

Increase Due to Corrected

Emission Factor

PM 25 8 0 0 8 PM10 15 9 0 0 9 PM2.5 10 9 0 0 9 CO 100 -253 0 0 -253 NOx 40 -26 0 0 -26 SO2 40 -171 0 0 -171

VOC 40 -19 0 0 -19 NMOC 50 -31 0 0 -31

H2S/TRS 10 0 0 0 0 HCl NA 9 0 9 0

GHG (CO2e) 75,000 398,300 278,900 119,400 0 31. The emissions increase over the netting basis is less than the significant emission rate for all pollutants

except greenhouse gas (GHG). No further analysis is required for these non-GHG pollutants. During the permit term a modification was approved that increased emissions over the significant emission rate for the non-GHG pollutants. A Prevention of Significant Deterioration (PSD) analysis was performed which included determination of Best Available Control Technology (BACT) and an ambient air quality impact analysis. The BACT limits are included in this permit and the ambient air quality analysis showed no adverse impact for any pollutant. At the time the PSD analysis was conducted biogenic greenhouse gases were not included in the emission calculations and the increase in GHG emissions was less than the SER. The inclusion of biogenic GHG causes the emission increase to be greater than the SER. A PSD review for GHG may be required for any physical change not currently approved, that results in an emissions increase. There is no SER for HCl so a comparison for this pollutant is not necessary.

BACT ANALYSIS 32. An analysis of the Best Available Control Technology (BACT) was conducted in the 6/18/12 ACDP. The

results are summarized below.

Emission Unit BACT Control Level of Control

Unpaved Roads (UPR) Application of water and dust suppressants Assumes 88% control efficiency

Paved Roads (PRD) Sweeping and application of water Assumes 79% control efficiency


Emission Unit BACT Control Level of Control Storage Piles (Piles) Application of water Assumes 70% control efficiency Petroleum Contaminated Soil (PCS)

Characterization to minimize amount of contamination None assumed

Landfill Gas (LFG) Active collection and control system As required in NSPS, Subpart WWW

Flares (FLR-1, FLR-2) LFG demisters/filters, good combustion practices

9.35 lb/MM ft3 LFG for PM/PM10/PM2.5 Limit 300 ppmv H2S in LFG 0.06 lb/MM ft3 LFG for NOx 0.2 lb/MM Btu for CO 98% destruction or 20 ppmv as hexane @ 3% O2 for VOC/NMOC

Landfill Gas Engines 1-8 (LFG ENG-1 through -8)

LFG demisters/filters, good combustion practices

0.1 g/hr-hr for PM/PM10/PM2.5 Limit 300 ppmv H2S in LFG 1.45 g/hp-hr for NOx 2.5 g/hp-hr for CO

Landfill Gas Engines 9-12 (LFG ENG-9 through -12)

LFG demisters/filters, good combustion practices

0.1 g/hr-hr for PM/PM10/PM2.5 Limit 300 ppmv H2S in LFG 0.60 g/hp-hr for NOx 3.6 g/hp-hr for CO 20 ppmv, dry as hexane @ 3% O2 or 98% by weight reduction for VOC/NMOC

BACT for GHG was not established in the previous permit. However, CO2 capture and sequestration has not been used at any other landfills. The best available control technology typically used at landfills is installation of an effective LFG collection system and an efficient system of destroying the methane in the LFG by combusting either in a flare or engine. No additional controls at Columbia Ridge will be required at this time to address greenhouse gas emissions.

HAZARDOUS AIR POLLUTANTS 33. A major source is a facility that has the potential to emit 10 tons/yr or more of any single HAP or 25 tons/yr

or more of combined HAPs. This source is not a major source of hazardous air pollutants. The HAP emissions detail is provided at the end of this report. Provided below is a summary of the HAP emissions.

Compound ton/yr

1,1,1-Trichloroethane 0.03 1,1,2,2-Tetrachloroethane 0.09 1,1,2-Trichloroethane 0.02 1,1-Dichloroethane 0.21 1,1-Dichloroethene 0.02 1,2-Dichloropropane 0.01 1,3-Butadiene 0.01 2,2,4-Trimethylpentane 0.07 4-Methyl-2-pentanone 0.09 Acetonitrile 0.02 Benzene 0.19 Carbon disulfide 0.01 Carbonyl sulfide 0.01 Chlorobenzene 0.05


Compound ton/yr Chlorodifluoromethane 0.07 Chloroethane 0.26 Chloroform 0.01 Chloromethane 0.01 Dichlorobenzene 0.14 Dichloromethane 0.52 Ethyl benzene 0.52 Ethylene dichloride (1,2-dichloroethane) 0.02

n-Hexane 0.27 Hydrochloric acid 9.41 Isopropylbenzene 0.05 Methyl ethyl ketone 0.29 Methyl tert-butyl ether 0.01 Naphthalene 0.01 Styrene 0.04 Tetrachloroethylene (Perchloroethylene) 0.34

Toluene 2.72 Trichloroethylene 0.11 Vinyl acetate 0.02 Vinyl chloride 0.09 Xylenes 0.98 Total 16.74

GENERAL BACKGROUND INFORMATION 34. This source is located in an area that is in attainment with all National Ambient Air Quality Standards

(NAAQS) and is not located within 100 km (62 miles) of any Class I area. 35. Other permits issued or required by DEQ for this source include a Storm Water Discharge Permit and a

Solid Waste Disposal Permit. 36. A Land Use Compatibility Statement signed by Gilliam County Planning Division on September 8, 1999

granted approval for the facility subject to siting, design, construction, or operational standards which has been subsequently complied with.

37. An Air Contaminant Discharge Permit (ACDP) was issued on 6/21/13 that allowed construction of 8 new

LFG engines after a Prevention of Significant Deterioration (PSD) review, including Best Available Control Technology (BACT) determination was performed. Four of the engines (LFG ENG -09 through -12) have been installed and are currently operating. The ACDP containing the PSD review was renewed on 6/23/16. The four engines that have not been installed will be allowed to operate under this permit as an alternative operating scenario. However, due to the time between issuance of the original PSD permit and construction of the last four engines DEQ will require an update to the BACT analysis to ensure that the most recent improvements to emission controls are included with the new engines. In addition, if the design of the last four engines is changed, a new ambient air quality analysis may be required. The potential changes in the BACT analysis and ambient air quality analysis need to be done in the ACDP. Therefore, DEQ is keeping the ACDP containing the PSD analysis active along with the renewed Title V


Permit. Any changes in the last four engines would be reflected in a modified ACDP which would then be incorporated into the Title V Permit.

COMPLIANCE HISTORY 38. The facility was inspected on 5/7/13, 5/26/15, and 8/25/17 and was found to be in compliance with all

permit conditions. 39. During the previous permit period no complaints were recorded for this facility. 40. No enforcement actions have been taken against this source during the previous permit term. SOURCE TEST RESULTS 41. The results of the most recent source tests are listed below:

Emission Unit Test Date Production Rate Pollutant Measured Value

Flare 1

11/6/07 2964 cfm LFG (57.1% methane)

SO2 3.55 lb/MM cf LFG CO 16.38 lb/MM cf LFG NOx 21.95 lb/MM cf LFG VOC 12.81 lb/MM cf LFG

NMOC 9 ppmv @ 3% O2 12.54 lb/MM cf LFG

2/17/10 1894 cfm LFG (54.3% methane)

SO2 11.6 lb/MM cf LFG CO 79.4 lb/MM cf LFG NOx 25.8 lb/MM cf LFG VOC <0.89 lb/MM cf LFG

NMOC <1.9 ppmv @ 3% O2

4/21/16 1300 cfm LFG (51% methane)

SO2 11.1 lb/MM cf LFG CO 51 lb/MM cf LFG NOx 30 lb/MM cf LFG

NMOC 0.97 ppmv @ 3% O2 1.6 lb/MM cf LFG

3/2/17 1,018 cfm LFG (53.6% methane) PM <0.003 gr/dscf

<16.5 lb/MM cf CH4

Flare 2

4/29/111 3412 cfm LFG (54.4% methane)

Particulate 39.7 lb/MM cf LFG SO2 9.2 lb/MM cf LFG

CO 27.5 lb/MM cf LFG 0.05 lb/MMBtu

NOx 35.9 lb/MM cf LFG

0.06 lb/MMBtu

VOC 5.4 lb/MM cf LFG 5.0 ppmvd as C6 @ 3% O2

NMOC 6.5 lb as C6/MMcf LFG

4/22/16 1243 cfm LFG (48.9% methane)

SO2 2.7 lb/MM cf LFG CO 5.9 lb/MM cf LFG NOx 22 lb/MM cf LFG

NMOC 0.32 ppmv @ 3% O2 0.4 lb/MM cf LFG



2/28/172 977.5 cfm LFG (53.6% methane) PM < 0.008 gr/dscf

< 35.2 lb/MM cf CH4

LFG Engine 1 5/10/10 282 cfm LFG 814 kW

Particulate 21.1 lb/MM cf LFG SO2 11.2 lb/MM cf LFG CO 303.8 lb/MM cf LFG NOx 187.4 lb/MM cf LFG

NMOC 4.8 ppmv @3% O2 4.7 lb/MM cf LFG

LFG Engine 2 5/10/10 280.5 cfm LFG 810 kW






LFG Engine 4

5/10/10 280.7 cfm LFG 829 kW



9/14/15 294 cfm LFG 831 kW

Particulate 0.1 g/BHP-hr (PM2.5)

0.03 gr/dscf 25.7 lb/MM cf LFG

SO2 4.72 ppmv

CO 2.34 g/BHP-hr 337.5 lb/MM cf LFG

NOx 0.88 g/BHP-hr

127.2 lb/MM cf LFG

LFG Engine 5

5/10/10 276.9 cfm LFG 812 kW



9/15/15 290 scfm LFG 827 kW

Particulate 0.1 g/BHP-hr (PM2.5)


SO2 5.06 ppmv


NOx 1.37 g/BHP-hr

199.6 lb/MM cf LFG



LFG Engine 6

5/10/10 273.0 cfm LFG 816 kW



9/20/16 284 cfm LFG 823 kW

Particulate 0.06 g/BHP-hr


SO2 44.8 ppm TRS


NOx 1.15 g/BHP-hr

171.6 lb/MM cf LFG




LFG Engine 8

5/10/10 286.1 cfm LFG 821 kW



9/20/16 282 cfm LFG 827 kW

Particulate 0.10 g/BHP-hr


SO2 22.74 ppmv TRS


NOx 1.24 g/BHP-hr

185.0 lb/MM cf LFG

LFG Engine 9

10/02/14 517.1 cfm LFG 1595 kW

Particulate 0.1 g/Bhp-hr 0.01 gr/dscf

15.5 lb/MM cf LFG SO2 1.37 ppmv H2S in LFG

CO 2.7 g/Bhp-hr 433.1 lb/MM cf LFG

NOx 0.57 g/Bhp-hr

91.0 lb/MM cf LFG

VOC <0.13 g/Bhp-hr

<14 ppmv @3% O2 <19 lb/MM cf LFG

9/15/15 524 cfm LFG 1634 kW

SO2 4.63 ppmv H2S in LFG


NOx 0.56 g/Bhp-hr

87.8 lb MM cf LFG



VOC <0.12 g/Bhp-hr


9/20/16 538 cfm LFG 1624 kW


NOx 0.49 g/BHP-hr

74.7 lb/MM cf LFG

VOC 0.2 g/Bhp-hr

18.6 ppmv @3% O2 25.1 lb/MM cf LFG

LFG Engine 10

10/02/14 510.2 cfm LFG 1573 kW




NOx 0.53 g/Bhp-hr

84.5 lb/MM cf LFG

VOC <0.12 g/Bhp-hr


9/14/15 556 cfm LFG 1633 kW



NOx 0.44 g/Bhp-hr

65.0 lb/ MM cf LFG

VOC <0.13 g/Bhp-hr


9/19/16 535 cfm LFG 1620 kW


NOx 0.59 g/Bhp-hr

90.7 lb/MM cf LFG

VOC 0.2 g/Bhp-hr

22.7 ppmv @3% O2 29.9 lb/MM cf LFG

LFG Engine 11

10/03/14 511.7 cfm LFG 1583 kW




NOx 0.55 g/Bhp-hr

88.9 lb/MM cf LFG

VOC ≤0.15 g/Bhp-hr

≤17 ppmv @3% O2 ≤23 lb/MM cf LFG

9/14/15 522 cfm LFG 1608 kW





NOx 0.49 g/Bhp-hr

77.6 lb/ MM cf LFG



9/19/16 546 cfm LFG 1636 kW


NOx 0.38 g/Bhp-hr

57.7 lb/MM cf LFG

VOC 0.1 g/Bhp-hr

7.8 ppmv @ 3% O2 10.4 lb/MM cf LFG

LFG Engine 12

10/03/14 511.1 cfm LFG 1582 kW




NOx 0.55 g/Bhp-hr

89.1 lb/MM cf LFG



9/15/15 517 cfm LFG 1629 kW



NOx 0.48 g/Bhp-hr

76.7 lb/MM cf LFG

VOC <0.13 g/Bhp-hr


9/19/16 547 cfm LFG 1628 kW


NOx 0.40 g/Bhp-hr

60.0 lb/MM cf LFG

VOC 0.1 g/Bhp-hr

11.1 ppmv @ 3% O2 14.0 lb/MM cf LFG

1. Stack diameter used in calculations may be incorrect. Results will not be used for compliance determination or emission factor determination until testing issues are resolved.

2. Back half of PM test for flare 2 indicates high condensable inorganics in exhaust. Source will investigate cause.


PUBLIC NOTICE 42. This permit was placed on public notice from Feb. 8, 2018 to Mar. 15, 2018. One comment was received

from the permittee. The comments are summarized in Attachment A - Response to Comments. After the comment period and hearing, if requested, DEQ will review the comments and modify the permit as may be appropriate. A proposed permit will be sent to EPA for a 45 day review period. DEQ may request and EPA may agree to an expedited review of 5 days if there were no substantive or adverse comments during the comment period.

If EPA does not object in writing, any person may petition the EPA within 60 days after the expiration of EPA's 45-day review period to make such objection. Any such petition must be based only on objections to the permit that were raised with reasonable specificity during the public comment period provided for in OAR 340-218-0210, unless the petitioner demonstrates it was impracticable to raise such objections within such period, or unless the grounds for such objection arose after such period.


ATTACHMENT A: RESPONSE TO COMMENTS Comment: The Plant Site Emission Limit (PSEL) was decreased in the renewal based on recent source test results. The PSEL should not be lowered, but should remain at the currently permitted levels. The currently permitted PSEL is based on PSD modeling and permitting, enforceable emission limits, and maximum equipment capacity specifications. The PSEL should not be based on current emissions, but on potential to emit at maximum capacity and guaranteed emission limits. For example the PSEL for SO2 is based not only on the concentration of sulfur in the landfill gas but on the quantity of gas destroyed. Columbia Ridge Landfill installed 13 additional landfill gas collection wells this year which will increase the collection rate of landfill gas resulting in an increase in SO2 emissions without an increase in sulfur concentration. Columbia Ridge must have the ability to increase gas collection in order to remain in compliance with the New Source Performance Standards (NSPS). Response: In accordance with OAR 340-222-0041(2) the PSEL is set equal to the lesser of the potential to emit, the netting basis, or a level requested by the applicant. DEQ believes the draft PSEL represents the potential to emit. The draft PSEL is based on the rated capacities of each unit as stated in the renewal application and in previous permit.

Emission Unit Rated Capacity Annual Capacity at 8760 hr/yr

Parameter used in draft PSEL calculation

Flare 1 4,000 standard ft3/minute 2,102 MMscf/yr 2,102 MMscf/yr Flare 2 4,000 standard ft3/minute 2,102 MMscf/yr 2,102 MMscf/yr Flare 3 1,350 standard ft3/minute 709.6 MMscf/yr 710 MMscf/yr Landfill Gas Engines 1-8

333 standard ft3/minute (each) 2,664 standard ft3/minute (combined)

1,400 MMscf/yr

1,400 MMscf/yr

Landfill Gas Engines 9-16

547 standard ft3/minute (each) 4,376 standard ft3/minute (combined)

2,300 MMscf/yr

2,300 MMscf/yr

Thus, the operating parameters used in the PSEL reflect the maximum potential throughput for each piece of equipment. The combined landfill gas capacity reflected in the PSEL is 8,614 MMscf/yr, which the renewal application indicates will not be generated by the landfill until 2042. This approach addresses the example stated in the comment. While 13 additional wells might increase the landfill gas collection rate, the proposed PSEL reflects the maximum capacity of the flares and landfill gas engines to combust the landfill gas and is not based on current landfill gas collection. This capacity is sufficient to accommodate installation of new wells. Installation of additional capacity will require a permit modification. The other factor used in establishing the PSEL is the emission factor. DEQ has an Internal Management Directive (IMD No: AQ.00.020, www.oregon.gov/deq/Filtered%20Library/IMDemissionfactor.pdf ) that discusses establishment of emission factors used in PSELs. This document indicates that PSELs are annual values and emission factors in the PSEL should normally use an average value rather than a value that is closer to the short-term worst case. Guaranteed emission limits and PSD limits often reflect a short-term worst case scenario and not an annual average. Permit writers must select the method that best approximates “actual emissions”. The directive then lists a hierarchy of the types of information to best approximate actual emissions. Source test data is considered to be more representative than emissions information from equipment vendors, particularly emission performance guarantees. The emission factors used in the proposed PSEL are averaged from multiple site-specific source tests performed over the past several years. DEQ believes these emission factors are representative and appropriate for use in the PSEL. These emission factors are also used to determine compliance with the PSEL. Therefore, the lower PSEL should not adversely affect compliance. DEQ will not modify the PSELs in the draft permit. If future source tests indicate the emission factors need to be modified, DEQ will take appropriate action.

http://www.oregon.gov/deq/Filtered%20Library/IMDemissionfactor.pdf


Comment: Request the 98% destruction efficiency requirement be removed from Condition 70.b. Landfill gas engines 9 through 16 use only treated LFG. The treatment system meets the requirements of 40 CFR 60.752(b)(2)(iii)(C). Response: The regulatory authority cited for Condition 70.b is the 6/21/13 ACDP Condition 2.8.a. That means that these limits were established under the authority of the PSD permit and represents a BACT limit and not just the NSPS limit. Modification of a BACT limit cannot be made in a Title V renewal unless it is first modified following the procedures used to establish the requirement initially (an ACDP/PSD modification). [OAR 340-218-0010(3)(b)(B)]


ATTACHMENT B: EMISSIONS DETAIL SHEETS Particulate Matter

Emission Point Operating Parameters Emission Factor Emissions

tons/yr Rate Reference

UPR - Unpaved Roads UPR-1 10,378 VMT/yr 0.60 lb/VMT AP-42 Sec. 13.2.21 3.13 UPR-2 48,028 VMT/yr 0.41 lb/VMT AP-42 Sec. 13.2.22 9.74 UPR-3 8,311 VMT/yr 0.43 lb/VMT AP-42 Sec. 13.2.23 1.77 Total 14.65 PRD - Paved Roads PRD-1 504,086 VMT/yr 0.13 lb/VMT AP-42 Sec. 13.2.14 32.78 PRD-2 53,025 VMT/yr 0.14 lb/VMT AP-42 Sec. 13.2.15 3.65 PRD-3 6,760 VMT/yr 0.39 lb/VMT AP-42 Sec. 13.2.16 1.33 PRD-4 15,587 VMT/yr 0.05 lb/VMT AP-42 Sec. 13.2.17 0.40 Total 38.16 MH - Material Handling 1,018,368 ton soil/yr 1.58E-04 lb/ton soil AP-42 Sec. 13.2.48 0.08 Piles Active days 2,024.88 acre-day/yr 1.9 lb/acre-day FIRE Database9 1.91 Inactive days 343.97 acre-day/yr 0.51 lb/acre-day FIRE Database10 0.09 Total 2.00 ENG Diesel (non-tipper) 162,200 hp-hr/yr 2.20E-03 lb/hp-hr AP-42, Table 3.3-1 0.18 Diesel (tipper) 1,383,200 hp-hr/yr 4.85E-04 lb/hp-hr Tier 2 40 CFR 89 0.34 Gas 10,500 hp-hr/yr 7.21E-04 lb/hp-hr AP-42, Table 3.3-1 0.004 Total 0.52 Flare11 FLR-1 2,102 MMdscf/yr 9.4 lb/MM ft3 AP-42 Table 2.4-4 9.83 FLR-2 2,102 MMdscf/yr 9.4 lb/MM ft3 AP-42 Table 2.4-4 9.83 FLR-3 710 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 3.32 Total 22.97 LFG Engines LF ENG-01 through 08 1,400 MMscf/yr 20.7 lb/MMscf ST 5/10, 9/15, 9/16 14.5 LFG ENG 09 through 16 2,300 MMscf/yr 16.9 lb/MMscf Source Test 10/14 19.4 Total 33.9 Aggregate Insignificant 1.0 Total Particulate Emissions 114 1. Equation 1a. k=4.9, s =6.2, a=0.7, W = 6.91, b=0.45, P = 120, 80% control due to watering. 2. Equation 1a. k=4.9, s =3.16, a=0.7, W = 25.43, b=0.45, P = 120, 88% control due to watering and dust suppressants. 3. Equation 1a. k=4.9, s =6.2, a=0.7, W = 7.06, b=0.45, P = 120, 86% control due to watering and dust suppressants. 4. Equation 1. k=0.011, sL =4.1, W = 16.07, P = 120, 79% control due to watering and sweeping. 5. Equation 1. k=0.011, sL =4.1, W = 17.00, P = 120, 79% control due to watering and sweeping. 6. Equation 1. k=0.011, sL =4.1, W = 47.46, P = 120, 79% control due to watering and sweeping. 7. Equation 1. k=0.011, sL =4.1, W = 6.48, P = 120, 79% control due to watering and sweeping. 8. Equation 1. k=0.74, U =10.83, M = 12, 70% control due to watering. 9. Assume 312 active days/yr. 70% control due to watering. 10. Assume 53 inactive days/yr. 70% control due to watering. 11. Capacity of enclosed flares is 4000 scfm. Capacity of utility flare is 1350 scfm.


PM10


tons/yr Rate Reference UPR - Unpaved Roads UPR-1 10,378 VMT/yr 0.16 lb/VMT AP-42 Sec. 13.2.21 0.84 UPR-2 48,028 VMT/yr 0.10 lb/VMT AP-42 Sec. 13.2.22 2.28 UPR-3 8,311 VMT/yr 0.11 lb/VMT AP-42 Sec. 13.2.23 0.48 Total 3.60 PRD - Paved Roads PRD-1 504,086 VMT/yr 0.03 lb/VMT AP-42 Sec. 13.2.14 6.56 PRD-2 53,025 VMT/yr 0.03 lb/VMT AP-42 Sec. 13.2.15 0.73 PRD-3 6,760 VMT/yr 0.08 lb/VMT AP-42 Sec. 13.2.16 0.27 PRD-4 15,587 VMT/yr 0.010 lb/VMT AP-42 Sec. 13.2.17 0.08 Total 7.63 MH - Material Handling 1,018,368 ton soil/yr 7.47E-05 lb/ton soil AP-42 Sec. 13.2.48 0.04 Piles Active days 2,024.88 acre-day/yr 0.9 lb/acre-day 50% of PM is PM10 0.96 Inactive days 343.97 acre-day/yr 0.26 lb/acre-day 50% of PM is PM10 0.04 Total 1.00 ENG Diesel (non-tipper) 162,200 hp-hr/yr 2.20E-03 lb/hp-hr AP-42, Table 3.3-1 0.18 Diesel (tipper) 1,383,200 hp-hr/yr 4.85E-04 lb/hp-hr Tier 2 40 CFR 89 0.34 Gas 10,500 hp-hr/yr 7.21E-04 lb/hp-hr AP-42, Table 3.3-1 0.004 Total 0.52 Flare9 FLR-1 2,102 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 9.83 FLR-2 2,102 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 9.83 FLR-3 710 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 3.32 Total 22.97 LFG Engines LF ENG-01 through 08 1,400 MMscf/yr 20.7 lb/MMscf Source Test 5/10 14.5 LFG ENG 09 through 16 2,300 MMscf/yr 16.9 lb/MMscf Source Test 10/14 19.4 Total 33.9 Aggregate Insignificant 1.0 Total PM10 Emissions 72 1. Equation 1a. k=1.5, s =6.2, a=0.9, W = 6.91, b=0.45, P = 120, 80% control due to watering. 2. Equation 1a. k=1.5, s =3.16, a=0.9, W = 25.43, b=0.45, P = 120, 88% control due to watering and dust suppressants. 3. Equation 1a. k=1.5, s =6.2, a=0.9, W = 7.06 , b=0.45, P = 120, 86% control due to watering and dust suppressants. 4. Equation 1. k=0.0022, sL =4.1, W = 16.07, P = 120, 79% control due to watering and sweeping. 5. Equation 1. k=0.0022, sL =4.1, W = 17.00, P = 120, 79% control due to watering and sweeping. 6. Equation 1. k=0.0022, sL =4.1, W = 47.46, P = 120, 79% control due to watering and sweeping. 7. Equation 1. k=0.0022, sL =4.1, W = 6.48, P = 120, 79% control due to watering and sweeping. 8. Equation 1. k=0.35, U =10.83, M = 12, 70% control due to watering. 9. Capacity of enclosed flares is 4000 scfm. Capacity of utility flare is 1350 scfm. Assume 55% of LFG is methane.


PM2.5


tons/yr Rate Reference UPR - Unpaved Roads UPR-1 10,378 VMT/yr 0.016 lb/VMT AP-42 Sec. 13.2.21 0.08 UPR-2 48,028 VMT/yr 0.010 lb/VMT AP-42 Sec. 13.2.22 0.23 UPR-3 8,311 VMT/yr 0.011 lb/VMT AP-42 Sec. 13.2.23 0.05 Total 0.36 PRD - Paved Roads PRD-1 504,086 VMT/yr 0.006 lb/VMT AP-42 Sec. 13.2.14 1.61 PRD-2 53,025 VMT/yr 0.007 lb/VMT AP-42 Sec. 13.2.15 0.18 PRD-3 6,760 VMT/yr 0.019 lb/VMT AP-42 Sec. 13.2.16 0.07 PRD-4 15,587 VMT/yr 0.003 lb/VMT AP-42 Sec. 13.2.17 0.02 Total 1.87 MH - Material Handling 1,018,368 ton soil/yr 1.13E-05 lb/ton soil AP-42 Sec. 13.2.48 0.01 Piles Active days 2,024.88 acre-day/yr 0.9 lb/acre-day All PM10 is PM2.5 0.96 Inactive days 343.97 acre-day/yr 0.26 lb/acre-day All PM10 is PM2.5 0.04 Total 1.00 ENG Diesel (non-tipper) 162,200 hp-hr/yr 2.20E-03 lb/hp-hr AP-42, Table 3.3-1 0.18 Diesel (tipper) 1,383,200 hp-hr/yr 4.85E-04 lb/hp-hr Tier 2 40 CFR 89 0.34 Gas 10,500 hp-hr/yr 7.21E-04 lb/hp-hr AP-42, Table 3.3-1 0.004 Total 0.52 Flare9 FLR-1 2,102 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 9.83 FLR-2 2,102 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 9.83 FLR-3 710 MMdscf/yr 9.4 lb/MMdscf AP-42 Table 2.4-4 3.32 Total 22.97 LFG Engines LF ENG-01 through 08 1,400 MMscf/yr 20.7 lb/MMscf Source Test 5/10 14.5 LFG ENG 09 through 16 2,300 MMscf/yr 16.9 lb/MMscf Source Test 10/14 19.4 Total 33.9 Aggregate Insignificant 1.0 Total PM2.5 Emissions 63

1. Equation 1a. k=0.15, s =6.2, a=0.9, W = 6.91, b=0.45, P = 120, 80% control due to watering. 2. Equation 1a. k=0.15, s =3.16, a=0.9, W = 25.43, b=0.45, P = 120, 88% control due to watering and dust suppressants. 3. Equation 1a. k=0.15, s =6.2, a=0.9, W = 7.06 , b=0.45, P = 120, 86% control due to watering and dust suppressants. 4. Equation 1. k=0.00054, sL =4.1, W = 16.07, P = 120, 79% control due to watering and sweeping. 5. Equation 1. k=0.00054, sL =4.1, W = 17.00, P = 120, 79% control due to watering and sweeping. 6. Equation 1. k=0.00054, sL =4.1, W = 47.46, P = 120, 79% control due to watering and sweeping. 7. Equation 1. k=0.00054, sL =4.1, W = 6.48, P = 120, 79% control due to watering and sweeping. 8. Equation 1. k=0.053, U =10.83, M = 12, 70% control due to watering. 9. Capacity of enclosed flares is 4000 scfm. Capacity of utility flare is 1350 scfm. Assume 55% of LFG is methane.


SO2



ENG Diesel 1,545,400 hp-hr/yr 2.05E-03 lb/hp-hr AP-42, Table 3.3-1 1.58 Gas 10,500 hp-hr/yr 5.91E-04 lb/hp-hr AP-42, Table 3.3-1 0.003 Total 1.59 Flare FLR-1 2,102 MMdscf LFG/yr 7.11 lb/MMdscf ST 03, 07, 10, 16 7.48 FLR-2 2,102 MMdscf LFG/yr 5.95 lb/MMdscf ST 11, 16 6.25 FLR-3 710 MMdscf LFG/yr 49.91 lb/MMdscf BACT, 300 ppm H2S 17.71 Total 31.44 LFG Engines LF ENG-01 through 08 1,400 MMdscf/yr 16.8 lb/MMdscf Source Test 5/10 11.8 LFG ENG 09 through 16 2,300.0 MMdscf/yr 0.8 lb/MMdscf Source Test 10/14, 9/15 0.8 Total 12.7 Aggregate Insignificant 1.0 Total SO2 Emissions 47

NOx



ENG Diesel (non-tipper) 162,200 hp-hr/yr 3.10E-02 lb/hp-hr AP-42, Table 3.3-1 2.51 Diesel (tipper) 1,383,200 hp-hr/yr 1.51E-02 lb/hp-hr Tier 2 40 CFR 89 10.44 Gas 10,500 hp-hr/yr 1.10E-02 lb/hp-hr AP-42, Table 3.3-1 0.058 Total 13.02 Flare FLR-1 2,102 MMdscf LFG/yr 24.7 lb/MMdscf ST 03, 07, 10, 16 26.00 FLR-2 2,102 MMdscf LFG/yr 28.8 lb/MMdscf ST 11, 16 30.27 FLR-3 710 MMdscf LFG/yr 33.0 lb/MMdscf BACT, 0.06 lb/MMBtu 11.71 Total 67.99 LFG Engines LF ENG-01 through 08 1,400 MMdscf/yr 179.4 lb/MMdscf ST 5/10, 9/15, 9/16 125.6 LFG ENG 09 through 16 2,300.0 MMdscf/yr 78.6 lb/MMdcsf ST 10/14, 9/15, 9/16 90.4 Total 216.0 Aggregate Insignificant 1.0 Total NOx Emissions 298


CO



ENG Diesel (non-tipper) 162,200 hp-hr/yr 6.68E-03 lb/hp-hr AP-42, Table 3.3-1 0.54 Diesel (tipper) 1,383,200 hp-hr/yr 8.16E-03 lb/hp-hr Tier 2 40 CFR 89 5.64 Gas 10,500 hp-hr/yr 6.96E-03 lb/hp-hr AP-42, Table 3.3-1 0.037 Total 6.22 Flare FLR-1 2,102 MMdscf LFG/yr 48.8 lb/MMdscf ST 07, 10, 16 51.33 FLR-2 2,102 MMdscf LFG/yr 16.7 lb/MMdscf ST 11, 16 17.56 FLR-3 710 MMdscf LFG/yr 110.0 lb/MMdscf BACT, 0.2 lb/MMBtu 39.03 Total 107.91 LFG Engines LF ENG-01 through 08 1,400 MMdscf/yr 295.7 lb/MMdscf ST 5/10, 9/15, 9/16 206.96 LFG ENG 9-16 2,300.0 MMdscf/yr 455.6 lb/MMdscf ST 10/14, 9/15, 9/16 523.89 Total 730.9 Aggregate Insignificant 1.0 Total CO Emissions 846

VOC



ENG Diesel 1,545,400 hp-hr/yr 2.47E-03 lb/hp-hr AP-42, Table 3.3-1 1.91 Gas 10,500 hp-hr/yr 1.50E-02 lb/hp-hr AP-42, Table 3.3-1 0.079 Total 1.99 LFG 672 MMcf/yr1 312.4 lb/MMdscf Source Estimate2 104.9 PCS Source Estimate 25.0 Flare FLR-1 2,102 MMdscf/yr 12.81 lb/MMdscf Source Test 11/07 13.47 FLR-2 2,102 MMdscf/yr 5.400 lb/MMdscf Source Test 4/11 5.68 FLR-3 710 MMdscf/yr 2.7 lb/MMdscf AP-42 0.96 Total 20.10 LFG Engines LF ENG-01 through 08 1,400 MMdscf/yr 5.4 lb/MMdscf Source Test 5/10 3.75 LFG ENG 09 through 16 2,300 MMdscf/yr 19.9 lb/MMdscf Source Test 9/16 22.83 Total 26.6 Aggregate Insignificant 1.0 Total VOC Emissions 180 1. LandGEM predicts 8519 cfm of LFG produced in 2021. Assume 85% is collected and 15% is emitted as fugitive. 2. Assumes 1396 ppmv VOC in the LFG, 86.18 g/mol VOC as hexane.


NMOC



LFG 672 MMcf/yr1 312.4 lb/MMdscf Source Estimate2 104.9 Flare FLR-1 2,102 MMdscf/yr 7.07 lb/MMdscf Source Test 11/07, 4/16 7.43 FLR-2 2,102 MMdscf/yr 0.40 lb/MMdscf Source Test 4/16 0.42 FLR-3 710 MMdscf/yr 2.7 lb/MMdscf AP-42 0.96 Total 8.81 LFG Engines LF ENG-01 through 08 1,400 MMdscf/yr 5.4 lb/MMdscf Same as VOC 3.75 LFG ENG 09 through 16 2,300 MMdscf/yr 19.9 lb/MMdscf Same as VOC 22.83 Total 26.6 Aggregate Insignificant 1.0 Total NMOC Emissions 141 1. LandGEM predicts 8519 cfm of LFG produced in 2021. Assume 85% is collected and 15% is emitted as fugitive. 2. Assumes 1396 ppmv NMOC in the LFG, 86.18 g/mol NMOC as hexane.

H2S/TRS



LFG 672 MMdscf/yr1 26.55 lb/MMdscf BACT, 300 ppm H2S 8.9 Flares (all) 4,914 MMdscf/yr 0.53 lb/MMdscf BACT, 300 ppm 98% DRE 1.3 LFG ENG (all) 3,700 MMdscf/yr 0.53 lb/MMdscf BACT, 300 ppm 98% DRE 1.0 Aggregate Insignificant 1.0 Total H2S/TRS Emissions 12.2 1. LandGEM predicts 8519 cfm of LFG produced in 2021. Assume 85% is collected and 15% is emitted as fugitive.


Greenhouse Gas



ENG Diesel CO2 1,545,400 hp-hr/yr 1.14 lb/hp-hr 40 CFR 98 Table C-1 881.9 CH4 (CO2e) 1.16E-03 lb/hp-hr1 40 CFR 98 Table C-2 0.89 N2O (CO2e) 0.003 lb/hp-hr2 40 CFR 98 Table C-2 2.13 Gas CO2 10,500 hp-hr/yr 1.08 lb/hp-hr 40 CFR 98 Table C-1 5.69 CH4 (CO2e) 1.16E-03 lb/hp-hr1 40 CFR 98 Table C-2 0.006 N2O (CO2e) 0.003 lb/hp-hr2 40 CFR 98 Table C-2 0.014 Total 890.67 LFG CO2 19,030 tons CO2/yr PSD Appl 19,0303 CH4 (CO2e) 6,784 tons CH4/yr 25 lb CO2e/lb CH4 GWP 169,5924

Total (not including CO2) 188,622 Flares (all) CO2 4,914 MMdscf/yr 103592.8 lb/MMdscf5 40 CFR 98 Table C-1 254,546 CH4 4,914 MMdscf/yr 81.6 lb/MMdscf6 40 CFR 98 Table C-2 200 N2O 4,914 MMdscf/yr 191.4 lb/MMdscf6 40 CFR 98 Table C-2 470 Total (not including CO2) 255,217 LFG Eng -01 through 08 CO2 1,400 MMdscf/yr 103592.8 lb/MMdscf5 40 CFR 98 Table C-1 72,515 CH4 (CO2e) 81.6 lb/MMdscf6 40 CFR 98, Table C-2 57.1 N2O (CO2e) 191.4 lb/MMdscf6 40 CFR 98, Table C-2 134.0 -09 through--16 CO2 2,300 MMdscf/yr 103592.8 lb/MMdscf5 40 CFR 98 Table C-1 119,132 CH4 (CO2e) 81.6 lb/MMdscf6 40 CFR 98 Table C-2 94 N2O (CO2e) 191.4 lb/MMdscf6 40 CFR 98 Table C-2 220 Total (not including CO2) 192,152 Aggregate Insignificant 2,756 Total GHG Emissions 639,638 1. Assumes global warming potential of 25 lb CO2e/lb CH4. 2. Assumes global warming potential of 298 lb CO2e/lb N2O. 3. LandGEM model in application predicts 8519 scfm LFG generation in 2021. Assume 45% of LFG is CO2. Assume 10% of

fugitive methane emitted is oxidized to CO2 at surface of landfill (40 CFR 98, Subpart HH). Assume 85% of LFG generated is captured and sent to flare/engines.

4. LandGEM model in application predicts 4686 scfm CH4 generation in 2021. Assume 10% of fugitive methane emitted is oxidized at surface of landfill (40 CFR 98, Subpart HH). Assume 85% of LFG generated is captured and sent to flare/engines.

5. Assume 45% of LFG is CO2 and passes through the device. Assume 55% of LFG is CH4 and subject to emission factor in 40 CFR 98 for combustion of biogas.

6. Assume LFG is 55% CH4 and global warming potential of 25 for CH4 and 298 for N2O.


BASELINE (2010) GREENHOUSE GAS



ENG Diesel CO2 1,065,838 hp-hr/yr 1.14 lb/hp-hr 40 CFR 98 Table C-1 608.26 CH4 (CO2e) 1.16E-03 lb/hp-hr1 40 CFR 98 Table C-2 0.62 N2O (CO2e) 0.003 lb/hp-hr2 40 CFR 98 Table C-2 1.47 Gas CO2 13,171 hp-hr/yr 1.08 lb/hp-hr 40 CFR 98 Table C-1 7.14 CH4 (CO2e) 1.16E-03 lb/hp-hr1 40 CFR 98 Table C-2 0.008 N2O (CO2e) 0.003 lb/hp-hr2 40 CFR 98 Table C-2 0.018 Total 617.50 LFG CO2 12,965 tons CO2/yr PSD Appl 12,9653 CH4 (CO2e) 4,621 tons CH4/yr 25 lb CO2e/lb CH4 GWP 115,5224

Total (not including CO2) 128,487 Flares (all) CO2 1,014 MMdscf/yr 103592.8 lb/MMdscf5 40 CFR 98 Table C-1 52,518 CH4 1,014 MMdscf/yr 81.6 lb/MMdscf6 40 CFR 98 Table C-2 41 N2O 1,014 MMdscf/yr 191.4 lb/MMdscf6 40 CFR 98 Table C-2 97 Total (not including CO2) 52,657 LFG Eng -01 through 08 CO2 1,094 MMdscf/yr 103592.8 lb/MMdscf5 40 CFR 98 Table C-1 56,645 CH4 (CO2e) 81.6 lb/MMdscf6 40 CFR 98, Table C-2 45 N2O (CO2e) 191.4 lb/MMdscf6 40 CFR 98, Table C-2 105 Total (not including CO2) 56,794 Aggregate Insignificant 2,756 Total GHG Emissions 241,311 1. Assumes global warming potential of 25 lb CO2e/lb CH4. 2. Assumes global warming potential of 298 lb CO2e/lb N2O. 3. LandGEM model in application predicts 5804 scfm LFG generation in 2010. Assume 45% of LFG is CO2. Assume 10% of

fugitive methane emitted is oxidized to CO2 at surface of landfill (40 CFR 98, Subpart HH). Assume 85% of LFG generated is captured and sent to flare/engines.

4. LandGEM model in application predicts 3192 scfm CH4 generation in 2010. Assume 10% of fugitive methane emitted is oxidized at surface of landfill (40 CFR 98, Subpart HH). Assume 85% of LFG generated is captured and sent to flare/engines.

5. Assume 45% of LFG is CO2 and passes through the device Assume 55% of LFG is CH4 and subject to emission factor in 40 CFR 98 for combustion of biogas.

6. Assume LFG is 55% CH4 and global warming potential of 25 for CH4 and 298 for N2O.


Hazardous Air Pollutants

Compound

IC Engines 3,933.04 MMBtu/yr

LFG Fugitives2

10,461,000 m3 CH4/yr Flares3

76,537,962.7 m3 CH4/yr LFG Engines6

58,060,798 m3 CH4/yr TOTAL tons/yr Emission

Factor1

lb/MMBtu

Emissions tons/yr

Emission Factor2

kg/m3 CH4

Emissions Emission Factor

kg/m3 CH4


kg/m3 CH4

Emissions

kg/yr tons/yr kg/yr tons/yr kg/yr tons/yr

1,1,1-Trichloroethane 2.41E-06 25.2 2.78E-02 5.54E-08 4.2 4.68E-03 6.75E-08 3.9 4.32E-03 3.25E-02 1,1,2,2,-Tetrachloroethane 6.68E-06 69.9 7.70E-02 1.54E-07 11.8 1.30E-02 1.87E-07 10.9 1.20E-02 9.00E-02 1,1,2-Trichloroethane 1.57E-06 16.4 1.81E-02 3.60E-08 2.8 3.04E-03 4.39E-08 2.6 2.81E-03 2.11E-02 1,1-Dichloroethane 1.53E-05 160.1 1.76E-01 3.52E-07 26.9 2.97E-02 4.29E-07 24.9 2.74E-02 2.06E-01 1,1-Dichloroethene 1.15E-06 12.1 1.33E-02 2.65E-08 2.0 2.24E-03 3.23E-08 1.9 2.07E-03 1.55E-02 1,2,4-Trichlorobenzene 7.43E-08 0.8 8.57E-04 1.71E-09 0.1 1.44E-04 2.08E-09 0.1 1.33E-04 1.00E-03 1,2-Dichloropropane 4.37E-07 4.6 5.04E-03 1.00E-08 0.8 8.48E-04 1.22E-08 0.7 7.83E-04 5.89E-03 1,3-Butadiene 3.91E-05 7.69E-05 6.68E-07 7.0 7.70E-03 1.54E-08 1.2 1.30E-03 1.87E-08 1.1 1.20E-03 9.07E-03 1,4,-Dioxane 5.43E-08 0.6 6.26E-04 1.25E-09 0.1 1.05E-04 1.52E-09 0.1 9.73E-05 7.32E-04 2,2,4-Trimethylpentane 5.22E-06 54.6 6.01E-02 1.20E-07 9.2 1.01E-02 1.46E-07 8.5 9.35E-03 7.03E-02 4-Methyl-2-pentanone 6.58E-06 68.8 7.58E-02 1.51E-07 11.6 1.28E-02 1.84E-07 10.7 1.18E-02 8.86E-02 Acetaldehyde 7.67E-04 1.51E-03 2.54E-07 2.7 2.92E-03 5.83E-09 0.4 4.92E-04 7.10E-09 0.4 4.54E-04 4.92E-03 Acetonitrile 1.7E-06 17.8 1.96E-02 3.90E-08 3.0 3.29E-03 4.75E-08 2.8 3.04E-03 2.29E-02 Acrolein 9.25E-05 1.82E-04 1.82E-04 Benzene 9.33E-04 1.83E-03 1.39E-05 145.8 1.61E-01 3.21E-07 24.5 2.70E-02 3.90E-07 22.7 2.50E-02 1.90E-01 Benzyl chloride 1.7E-07 1.8 1.96E-03 3.92E-09 0.3 3.31E-04 4.77E-09 0.3 3.05E-04 2.30E-03 Bromomethane 1.48E-07 1.6 1.71E-03 3.41E-09 0.3 2.88E-04 4.15E-09 0.2 2.66E-04 2.00E-03 Carbon disulfide 8.32E-07 8.7 9.60E-03 1.91E-08 1.5 1.62E-03 2.33E-08 1.4 1.49E-03 1.12E-02 Carbon tetrachloride 9.13E-08 1.0 1.05E-03 2.10E-09 0.2 1.77E-04 2.56E-09 0.1 1.64E-04 1.23E-03 Carbonyl sulfide 5.45E-07 5.7 6.28E-03 1.25E-08 1.0 1.06E-03 1.53E-08 0.9 9.77E-04 7.34E-03 Chlorobenzene 4.05E-06 42.4 4.67E-02 9.32E-08 7.1 7.86E-03 1.13E-07 6.6 7.26E-03 5.46E-02 Chlorodifluoromethane 5.12E-06 53.5 5.90E-02 1.18E-07 9.0 9.93E-03 1.43E-07 8.3 9.17E-03 6.90E-02 Chloroethane 1.89E-05 198.2 2.18E-01 4.36E-07 33.4 3.68E-02 5.31E-07 30.8 3.40E-02 2.55E-01 Chloroform 6.29E-07 6.6 7.25E-03 1.45E-08 1.1 1.22E-03 1.76E-08 1.0 1.13E-03 8.47E-03 Chloromethane 9.16E-07 9.6 1.06E-02 2.11E-08 1.6 1.78E-03 2.57E-08 1.5 1.64E-03 1.23E-02 Dichlorobenzene 1.03E-05 107.5 1.18E-01 2.36E-07 18.1 1.99E-02 2.88E-07 16.7 1.84E-02 1.38E-01 Dichloromethane 3.88E-05 406.3 4.48E-01 8.93E-07 68.4 7.54E-02 1.09E-06 63.1 6.96E-02 5.23E-01 Ethylbenzene 3.84E-05 401.4 4.42E-01 8.82E-07 67.5 7.45E-02 1.07E-06 62.4 6.88E-02 5.17E-01 Ethylene dibromide 6.71E-08 0.7 7.73E-04 1.54E-09 0.1 1.30E-04 1.88E-09 0.1 1.20E-04 9.03E-04 Ethylene dichloride 1.17E-06 12.2 1.35E-02 2.69E-08 2.1 2.27E-03 3.28E-08 1.9 2.10E-03 1.58E-02


Compound

IC Engines 3,933.04 MMBtu/yr

LFG Fugitives2

10,461,000 m3 CH4/yr Flares3

76,537,962.7 m3 CH4/yr LFG Engines6

58,060,798 m3 CH4/yr TOTAL tons/yr Emission

Factor1

lb/MMBtu

Emissions tons/yr

Emission Factor2

kg/m3 CH4


kg/m3 CH4


kg/m3 CH4

Emissions

kg/yr tons/yr kg/yr tons/yr kg/yr tons/yr

Formaldehyde 1.18E-03 2.32E-03 2.61E-08 0.3 3.01E-04 6.01E-10 0.05 5.07E-05 7.32E-10 0.04 4.68E-05 2.67E-03 Hexachlorobutadiene 6.77E-08 0.7 7.80E-04 1.56E-09 0.1 1.31E-04 1.89E-09 0.1 1.21E-04 9.12E-04 n-Hexane 1.99E-05 207.8 2.29E-01 4.57E-07 35.0 3.85E-02 5.56E-07 32.3 3.56E-02 2.68E-01 Hydrochloric acid 1.12E-044 8540.0 9.41E+00 1.11E-044 6440.0 7.10E+00 9.41 Isopropylbenzene 3.84E-06 40.2 4.43E-02 8.84E-08 6.8 7.46E-03 1.08E-07 6.3 6.89E-03 5.18E-02 Mercury 1.82E-09 0.01 2.10E-05 1.82E-095 0.1 1.54E-04 1.82E-095 0.1 1.16E-04 1.75E-04 Methyl ethyl ketone 2.15E-05 224.9 2.48E-01 4.95E-07 37.9 4.17E-02 6.02E-07 35.0 3.85E-02 2.90E-01 Methyl tert-butyl ether 7.73E-07 8.1 8.92E-03 1.78E-08 1.4 1.50E-03 2.17E-08 1.3 1.39E-03 1.04E-02 Naphthalene 8.48E-05 1.67E-04 1.02E-06 10.7 1.18E-02 2.35E-08 1.8 1.98E-03 2.86E-08 1.7 1.83E-03 1.39E-02 Styrene 3.18E-06 33.3 3.67E-02 7.32E-08 5.6 6.18E-03 8.91E-08 5.2 5.70E-03 4.29E-02 Tetrachloroethylene 2.5E-05 261.9 2.89E-01 5.76E-07 44.1 4.86E-02 7.01E-07 40.7 4.49E-02 3.37E-01 Toluene 4.09E-04 8.04E-04 2.02E-04 2114.4 2.33E+00 4.65E-06 356.0 3.92E-01 5.66E-06 329.0 3.62E-01 2.72 Tribromomethane 2.33E-07 2.4 2.69E-03 5.36E-09 0.4 4.52E-04 6.52E-09 0.4 4.18E-04 3.14E-03 Trichloroethylene 8.09E-06 84.6 9.33E-02 1.86E-07 14.2 1.57E-02 2.27E-07 13.2 1.45E-02 1.09E-01 Vinyl acetate 1.59E-06 16.6 1.83E-02 3.65E-08 2.8 3.08E-03 4.45E-08 2.6 2.85E-03 2.14E-02 Vinyl chloride 6.6E-06 69.0 7.61E-02 1.52E-07 11.6 1.28E-02 1.85E-07 10.7 1.18E-02 8.89E-02 Xylenes 2.85E-04 5.60E-04 7.29E-05 762.3 0.84 1.68E-06 128.0 1.41E-01 2.04E-06 118.0 1.31E-01 9.82E-01 TOTAL 16.74

1. AP-42 Table 3.2-2 2. Methane generation from LandGEM model for 2021. Assumes 85% of LFG is collected. Emission factor from AP-42 Section 2.4 (Oct 2008) Equations 3 and 4,

Table 2.4-1. 3. Assumes all flares operating at capacity. Emission factor from AP-42 Section 2.4 (Oct 2008) Equations 3 and 4, Table 2.4-1. Control efficiency of 97.7% from

Table 2.4-3. 4. Hydrochloric acid emission factor from AP-42 Section 2.4 (Oct 2008) Equations 9 and 10. Assumes 42 ppm chloride compounds in LFG, 97.7% of which are

oxidized and available to form HCl. 5. No control efficiency for mercury emissions. 6. Assumes all LFG engines operating at capacity. Emission factor from AP-42 Section 2.4 (Oct 2008) Equations 3 and 4, Table 2.4-1. Control efficiency of 97.2%

from Table 2.4-3

Documents

OREGON DEPARTMENT OF ENVIRONMENTAL … gas (LFG) collection system. The landfill gas is either sent to enclosed flares or to landfill gas The landfill gas is either sent to enclosed