PERMIT MEMORANDUM 2005-248-TVR - 10 -
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY DRAFT
AIR QUALITY DIVISION
MEMORANDUM December 27, 2006
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH: Kendal Stegmann, Supervising Attorney, Air Quality Division
THROUGH: Rick Groshong, Environmental Program Manager, Enforcement Section
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
THROUGH: Phil Martin, P.E., New Source Permits Section
THROUGH: Peer Review
FROM: Dale Becker, P.E., New Source Permits Section
SUBJECT: Evaluation of Permit Application No. 2005-248-TVR
Oklahoma City Landfill, LLC
Southeast Oklahoma City Landfill
7001 South Bryant Street, Oklahoma City, Oklahoma
Section 25, T11N, R3W, Lat. 35.396˚ Long. -97.459˚
Directions: I-240 and Bryant Street in Oklahoma City
SECTION I. INTRODUCTION
The Southeast Oklahoma City Landfill (Southeast) is an active municipal solid waste landfill for non-hazardous solid waste (SIC 4953) and asbestos containing wastes. The landfill began receiving refuse in 1965 and has a design capacity of 11,375,151 megagrams (Mg) of refuse. The facility is owned and operated by Oklahoma City Landfill, LLC. The facility was issued Title V Permit No. 99-401-TV on May 29, 2001. On August 22, 2002, the facility submitted an application for the installation of a soil vapor vent/flare. On December 17, 2002, the facility submitted a Tier 2 Non-methane Organic Compound (NMOC) Emission Rate Report to ODEQ. The report indicated that the 2002 NMOC emission rate was above the NSPS applicability threshold of 50 megagrams per year (Mg/yr). As a result, the facility submitted a Gas Collection and Control System (GCCS) Design Plan on December 12, 2003. The facility is currently operating under Permit No. 99-401-TV (M-1) which incorporated the GCCS into its Title V permit.
SECTION II. FACILITY DESCRIPTION
Southeast currently operates an active GCCS in the landfill. The GCCS conveys the extracted landfill gas (LFG) to an existing LFG processing/flare facility owned and operated by Oklahoma Gas Producers, LLC (OGP) which is owned by DTE Biomass Energy Services (DTE). The facility also has a soil vapor extraction system that collects vapor from soils and conveys it to a vent/flare to be combusted or directly vented to the atmosphere.
OGP owns the rights to extract the LFG from the facility and processes the majority of the extracted LFG to be sold as medium-Btu fuel to an offsite consumer. The remaining extracted LFG is diverted to the utility vent/flare.
SECTION III. EMISSIONS
The facility includes the following emission sources:
· MSW Landfill – fugitive emissions from the decomposition of organic materials,
· Vent/Flare – emissions generated from the combustion of soil vapors,
· Earthmoving Equipment Operations – fugitive particulate emissions generated from landfill earthmoving equipment operations.
1. Uncontrolled NMOC emissions for the landfill (with no GCCS) were estimated using EPA’s Landfill Gas Emissions Model and calculated to be 73.26 Mg/year (80.77 TPY) in the year of closing, 2017.
2. The emission estimates for the vent/flare were based on a worst-case scenario where the maximum soil vapor flow rate to the vent/flare is 500 scfm. The concentration for Nitrogen Oxides (NOx), Sulfur Dioxide, (SO2), Hazardous Air Pollutants (HAPs), Carbon Monoxide (CO) and Particulates (PM10) are based on the Environmental Protection Agency's (EPA's) Compilation of Air Pollutant Emission Factors, AP-42, 11/98 for MSW landfills.
3. The concentration for Volatile Organic Compounds (VOCs) is based on site-specific sampling from the landfill and AP-42, 11/98 standards.
4. The vent/flare destruction efficiency of VOCs and all HAPs, except Hydrogen Chloride (HCl), is 98%. This destruction efficiency estimate is widely accepted within the industry for vent/flares similar to the one installed.
5. Estimates of HAP emissions are based on LFG constituent concentrations in AP-42, 11/98.
6. Estimates of emissions from earth moving equipment operation are based on EPA’s Compilation of Air Pollutant Emission Factors (AP-42) Chapters 11 and 13.
Potential Facility Emissions
Source / HAP1 / CO / NOx / SO2 / HCl / PM2.5/10 / VOC2Vent/Flare / 2.44 / 22.12 / 2.63 / 1.01 / 0.5 / 1.1 / 4.53
Ldfl Fugitive / 15.53 / -- / -- / -- / -- / -- / 28.58
Earth Moving3 / -- / -- / -- / -- / -- / 2.5 / --
Total / 17.97 / 22.12 / 2.63 / 1.01 / 0.5 / 3.6 / 33.11
1based on the maximum estimated LFG generation.
2VOC concentration is calculated as 36% of the site specific NMOC concentration as per LandGEM version 3.02.
3Fugitive emissions from processes such as vehicle traffic are not federally regulated, however the specific conditions will require reasonable precautions be taken to minimize fugitive dust from all activities.
Potential Hazardous Air Pollutants (From Landfill Gas)
Toxic Air Pollutants / MolecularWeight / Site-specific
ppmv / Emissions
TPY
1,1,1-Trichloroethane / 133.41 / 0.35 / 0.099
1,1,2,2-Tetrachloroethane / 167.85 / 0.81 / 0.286
1,1-Dichloroethane (ethylidene dichloride) / 98.97 / 1.76 / 0.367
1,1-Dichloroethene (vinylidene chloride) / 96.94 / 0.15 / 0.03
1,2-Dichloroethane (ethylene dichloride) / 98.96 / 0.30 / 0.063
1,2-Dichloropropane (propylene dichloride) / 112.99 / 0.13 / 0.031
Acrylonitrile / 53.06 / 4.61 / 0.517
Benzene / 78.11 / 1.39 / 0.23
Carbon disulfide / 76.13 / 0.42 / 0.068
Carbon tetrachloride / 153.84 / 0.003 / 0.001
Carbonyl sulfide / 60.07 / 0.36 / 0.046
Chlorobenzene / 112.56 / 0.18 / 0.044
Chloroethane / 64.52 / 0.95 / 0.13
Chloroform / 119.39 / 0.02 / 0.006
Chloromethane / 50.49 / 0.88 / 0.094
Dichloromethane / 84.89 / 10.25 / 1.839
Ethylbenzene / 106.16 / 3.37 / 0.755
Ethylene dibromide / 187.88 / 0.001 / 0.000
Hexane / 86.18 / 4.83 / 0.88
Mercury / 200.61 / 0.0002 / 0.000
Methyl isobutyl ketone / 100.16 / 1.39 / 0.294
Perchloroethylene / 165.83 / 2.71 / 0.949
Toluene / 92.13 / 28.55 / 5.557
Trichloroethylene / 131.40 / 2.05 / 0.569
Vinyl chloride / 62.50 / 5.34 / 0.706
Xylenes / 106.16 / 8.78 / 1.97
Total / 15.53
HAP emissions are below major source levels.
SECTION IV. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application and listed in OAC 252:100-8, Appendix I, are duplicated below. Record keeping, for activities indicated with an “*”, is required in the Specific Conditions.
1. Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. There are a 500-gallon gasoline storage tank, an 8,000-gallon and a 500-gallon diesel storage tank with an average throughput less than the de minimis.
2. *Activities having the potential to emit no more than 5.0 TPY (actual) of any criteria pollutant. A 100,000-gallon leachate tank is present. Others may be added in the future.
SECTION V. OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements.
OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]
Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards.
OAC 252:100-4 (New Source Performance Standards) [Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they existed on September 1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart BBBB, Subpart DDDD, Subpart HHHH and Appendix G. NSPS requirements are addressed in the “Federal Regulations” section.
OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories have been submitted and fees paid for the past years.
OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]
Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility that result in emissions not authorized in the permit and that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities refer to those individual emission units either listed in Appendix I or whose actual calendar year emissions do not exceed the following limits.
· 5 TPY of any one criteria pollutant
· 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule
The facility is classified a Part 70 source as specified in NSPS Subpart WWW since design capacity of the landfill is greater than 2.5 million megagram or 2.5 million m3. As such, a Title V (Part 70) operating permit is required.
OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]
In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility.
OAC 252:100-13 (Open Burning) [Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.
OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity.
OAC 252:100-29 (Fugitive Dust) [Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Fugitive dust emissions from traffic on paved and unpaved roads are controlled using water spray with 90% control efficiency. The permittee will be required to take reasonable precautions to minimize fugitive dust.
OAC 252:100-37 (Volatile Organic Compounds) [Applicable]
Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The 500 gallon gasoline storage tank is storing organic materials with a vapor pressure greater than 1.5 psia.
Part 5 limits the organic solvent content of coating of parts and products. There is no coating operation at this facility.
Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions of VOC. There is no such equipment at this location.
Part 7 requires all effluent water separators, which receive water containing more than 200 gallons per day of any VOC, openings to be sealed or the separator to be equipped with an external floating roof or a fixed roof with an internal floating roof or a vapor recovery system. No effluent water separators are located at this facility.
Part 7 also requires all reciprocating pumps and compressors handling VOCs to be equipped with packing glands that are properly installed and maintained in good working order and rotating pumps and compressors handling VOCs to be equipped with mechanical seals. There is no such equipment at this location.
OAC 252:100-41 (Hazardous Air Pollutants) [Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on September 1, 2005, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG, HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE, FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, RRRRR, SSSSS and TTTTT are hereby adopted by reference as they exist on September 1, 2005. These standards apply to both existing and new sources of HAPs. These requirements are covered in the “Federal Regulations” section.
Part 5 was a state-only requirement governing sources of toxic air contaminants that have emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded by OAC 252:100-42, effective June 15, 2006.
OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]
Part 5 of OAC 252:100-41 was superseded by this subchapter. Any work practice, material substitution, or control equipment required by the Department prior to June 11, 2004, to control a TAC, shall be retained unless a modification is approved by the Director. Since no Area of Concern (AOC) has been designated anywhere in the state, there are no specific requirements for this facility at this time.
OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice of intent-to-test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.