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Home My WebLink About20180806.tiffL&blit_ Rei►4,w COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 March 12, 2018 Dear Sir or Madam: RECEIVED MAR 1 5 zot8 WOOMMISS COUNT), On March 15, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Denver Regional Landfill (South) Inc. - Denver Regional Landfill South. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CZ: PLC A l-rP), E4L- CST) ?W (ERfC3 rl� ( 1.) 0 2018-0806 Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Denver Regional Landfill (South) Inc. - Denver Regional Landfill South - Weld County Notice Period Begins: March 15, 2018 NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: Denver Regional Landfill (South) Inc. 1441 Weld County Road Six, P.O. Box 320 Erie, Co 80516 Facility: Denver Regional Landfill South 1441 Weld County Road Six Erie, Co 80516 Denver Regional Landfill (South) Inc. has applied to renew the Operating Permit for the Denver Regional Landfill South in Weld County, CO. Denver Regional Landfill South (DRLS) is a municipal solid waste landfill and falls under the Standard Industrial Classification 4953. Landfill gas is generated from the decomposition of organic materials found in landfills. Landfill gas is primarily composed of methane and carbon dioxide. Volatile organic compounds (VOC) and hazardous air pollutants (HAP) are present in landfill gas. Landfill gas can be emitted through cover soils but, a portion of the gas is collected and controlled with a landfill gas collection and control system (GCCS). Collected landfill gas is sent to the flare for destruction and/or to a third party facility. During its operation, the flare generates various combustion by-products that are emitted into the atmosphere. Particulate emissions are generated from construction and operation of the landfill, which includes vehicle traffic on paved or unpaved roads, excavation, and the handling of soil cover material. The Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits Emission limits were not modified excluding VOCs from the uncollected landfill gas. These emissions increased slightly due to the capacity change and using the current standard for calculating landfill emissions. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 03OPWE254 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are. available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public- notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jayson Ellis of the Division at 303-692-3208 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group tract cot 1 0 AP requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. Amy cQLO ADO 2 I xu , Colorado Department of Public Health and Environment OPERATING PERMIT Denver Regional Landfill (South) Inc. DRAFT First Issued: March 1, 2006 Renewed: XXX 1, 2018 AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Denver Regional OPERATING PERMIT NUMBER Landfill (South) Inc. FACILITY ID: 1230079 ISSUE DATE: XXXX , 2018'. EXPIRATION DATE: XXXXX 1, 2023 MODIFICATIONS: See Appendix F of Permit 1 03OPWE254 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sec . and applicable rules and regulations. ISSUED TO: Denver Regional Landfill (South) Inc. 1441 Weld County Road Six, P.O. Box 320 Erie, CO 80516 PLANT SITE LOCATION: 1441 Weld County Road Six Erie, CO Weld County INFORMATION RELIED UPON Renewal Application Received: And Additional Information Received: March 1, 2010 September 13, 2010 Nature of Business: Municipal solid waste disposal Primary SIC: 4953 RESPONSIBLE OFFICIAL Name: Randy Tourville Title: District Manager FACILITY CONTACT PERSON Name: Kyle Regan Title: Technical Engineering Supervisor Phone: 303-673-9431 Phone: 408-930-2544 SUBMITTAL DEADLINES Seim Annual Monitoring Period: 1'I3DJanuary 1— June 30, July 1— Decembers 31 Semi -Annual Monitoring Report: TBDDue on August 1, 2006 & February 1, 2007 and subsequent years Annual Compliance Period: TBDlanuary 1 to December 31 Annual Compliance Certification: TBDDue- on February 1, 2007 and subsequent years Note that the Semi -Annual Monitoring Reports and Annual Compliance Certifications must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports/certifications. TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Prevention Of Significant Deterioration (PSD) 2 4. Accidental Release Prevention Program (112(r)) 2 5. Compliance Assurance Monitoring (CAM) 2 6. Summary of Emission Units 2 SECTION II - Specific Permit Terms 4 1. F001 —Uncollected Landfill Gas Emissions 4 2. C001 — Gas Collection and Control System 6 3. F003 — Fugitive Particulate Matter Emissions 15 SECTION III - Permit Shield 16 1. Specific Non -Applicable Requirements 16 2. General Conditions 16 3. Stream -lined Conditions 16 SECTION IV - General Permit Conditions ver 5/22/12 17 1. Administrative Changes 17 2. Certification Requirements 17 3. Common Provisions 17 4. Compliance Requirements 21 5. Emergency Provisions _ 22 6. Emission Controls for Asbestos 22 7. Emissions Trading, Marketable Permits, Economic Incentives 22 8. Fee Payment 22 9. Fugitive Particulate Emissions 23 10. Inspection and Entry 23 11. Minor Permit Modifications 23 12. New Source Review 23 13. No Property Rights Conveyed 23 14. Odor 23 15. Off -Permit Changes to the Source 23 16. Opacity 24 17. Open Burning 24 18. Ozone Depleting Compounds 24 19. Permit Expiration and Renewal 24 20. Portable Sources 24 21. Prompt Deviation Reporting 24 22. Record Keeping and Reporting Requirements 25 23. Reopenings for Cause 26 24. Section 502(b)(10) Changes 26 25. Severability Clause 26 26. Significant Permit Modifications 27 27. Special Provisions Concerning the Acid Rain Program 27 28. Transfer or Assignment of Ownership 27 29. Volatile Organic Compounds 27 30. Wood Stoves and Wood burning Appliances 28 TABLE OF CONTENTS: APPENDIX A - Inspection Information 1 Directions to Plant: 1 Safety Equipment Required: 1 Facility Plot Plan• 1 List of Insignificant Activities: 1 Appendix B Reporting Requirements and Definitions 1 APPENDIX B: Monitoring and Permit Deviation Report - Part I 5 APPENDIX B: Monitoring and Permit Deviation Report - Part II 6 APPENDIX B: Monitoring and Permit Deviation Report - Part III 8 APPENDIX C - Required Format for Annual Compliance Certification Reports 1 APPENDIX D 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 1. Permitted Activities 1.1 Denver Regional Landfill (South) Inc. Page 1 SECTION I - General Activities and Summary Denver Regional Landfill South (DRLS) is a municipal solid waste landfill and falls under the Standard Industrial Classification 4953. Landfill gas is generated from the decomposition of organic materials found in landfills. Landfill gas is primarily composed of methane and carbon dioxide. Volatile organic compounds (VOC) and hazardous air pollutants (HAP) are present in landfill gas. Landfill gas can be emitted through cover soils but, a portion of the gas is collected and controlled with a landfill gas collection and control system (GCCS). Collected landfill gas is sent to the flare for destruction and/or to a third party facility. During its operation, the flare generates various combustion by-products that are emitted into the atmosphere. Particulate emissions are generated from construction and operation of the landfill, which includes vehicle traffic on paved or unpaved roads, excavation, and the handling of soil cover material. This facility is located at 1441 Weld County Road Six, Erie, Weld County. The area is classified as non -attainment for ozone and is part of the 8 -hour Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of this facility. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park, and Rawah Wilderness Area. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 The Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permit: 12WE652. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV, Conditions 14 and 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 2 2. Alternative Operating Scenarios 2.1 The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 2.1.1 No separate operating scenarios have been specified. 3. Prevention Of Significant Deterioration (PSD) 3.1 DRLS is located adjacent to the Denver Regional Landfill North, the Front Range landfill, and the Timberline Energy facility and they are considered to be a single stationary source for purposes of Title V, PSD, and NANSR. This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. This facility is categorized as a PSD major stationary source (Potential to emit > 250 Tons/Year for CO). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (Potential to Emit of > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 3.2 Operating Permits 99OPWE215, 97OPWE188 and 12OPWE376 are to be considered in conjunction with this operating permit for purposes of determining the applicability or non - applicability of Prevention of Significant Deterioration (PSD) regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based upon the information provided by the applicant, the sources addressed in this permit are not subject to the provisions of the Accidental Release Prevention Program (section 112(r) of the Federal Clean Air Act). 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: None. 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 3 Emission Unit AIRS Stack Unit ID Description Pollution Control Device F001 001 LF-1 Uncollected landfill gas emissions N/A C001 001 GF-1 Gas collection and control system Air -Assisted Enclosed Flare F003 001 CV -1, PR -1, UPR-1, SP -1 Fugitive particulate emissions Fugitive Emission Control Plan Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 4 SECTION II - Specific Permit Terms 1. F001 —Uncollected Landfill Gas Emissions Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission Limits 1.1 VOC: 33.0 tons/year CO: 3.0 tons/year EPA Landfill Gas Estimation Model or EPA AP -42 2.4 Recordkeeping & Calculation Annual PCS Acceptance Determination 1.2 PCS Exposure Time 1.3 Cover by end of day Waste Acceptance Design Capacity 1.4 1.5 1,500,000 tons/year 14,147,836 Mg See PS Memo #12-01 Recordkeeping/ Calculation Monthly/ Annually Recordkeeping See Condition 1.3 Recordkeeping Monthly See Condition 1.5 1.1 Emissions of Volatile Organic Compounds (VOC), and CO from the landfill shall not exceed the annual limits in the table above. Landfill gas emissions are calculated annually, and monthly limits and calculations do not apply. The emissions shall be calculated by March 1st of each year beginning in 2019 using EPA's Landfill Gas Emissions Model (Version 3.02 or the most current version of the model). The calculation shall use the actual waste acceptance rates as described in Condition 1.4 and from previous years. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested emissions identified on the APEN submitted on January 16, 2018) The mass of non -degradable solid waste may be deducted from the total waste acceptance when calculating emissions if adequate documentation of the nature and amount of such wastes is maintained. Adequate documentation shall include the waste characterization procedures and recordkeeping format used. Exclusion of nondegradeable waste from the emissions calculations is subject to Division review and approval, and records shall be provided for Division inspection upon request. The following parameters shall be used when calculating emissions to monitor compliance with the annual emission limits of this permit, unless other parameters are approved in advance by the Division. Note that these parameters may not be acceptable for emission calculations associated with the federal New Source Performance Standards or Emission Guidelines. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 5 Parameter Small Quantities of PCS Considerable Quantities of PCS Methane Generation Rate Constant "k" . 0.02 or valid Tier 3 test result 0.02 or valid Tier 3 test result Methane Generation Potential "La" 100 100 NMOC (as hexane) 956 ppmv or valid Tier 2 test result 2420 ppmv or valid Tier 2 test result Benzene 1.9 ppmv 11.1 ppmv Toluene 39 ppmv 170 ppmv VOC 39% of NMOC 85% of NMOC Other HAPs As defined by AP -42 Chapter 2.4 1.2 Acceptance of Petroleum Contaminated Soils (PCS) shall be tracked on a monthly basis and an annual total shall be maintained. By February 1st of each year, the source shall determine the percentage of PCS to total waste accepted in the previous calendar year, and if desired, on a five (5) year average. This calculation shall be used to determine the appropriate emissions calculation methodology as described in PS Memo #12-01 and Condition 1.1 of this section. If the facility begins taking considerable quantities of PCS, a permit modification may be required. Records of PCS acceptance and of PCS as a percentage of total waste shall be maintained and made available for inspection upon request. (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part A, Section I.B.36.h, and Part C, Section III.B.7 based on requested emissions identified on the APEN submitted on January 16, 2018) 1.3 This landfill is subject to Regulation 7, Section V which prohibits disposal of Volatile Organic Compounds (VOCs) by evaporation without utilizing RACT. VOC-impacted soils, including Petroleum Contaminated Soils (PCS), shall be landfilled and covered as soon as practical but no later than 24 hours after they are accepted. VOC-impacted soils shall not be used for alternate daily cover and shall not be stored anywhere at the facility to allow them to dry. These practices are considered RACT for the PCS acceptance operations. (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part A, Section I.B.36.h, and Part C, Section III.B.7 based on requested emissions identified on the APEN submitted on January 16, 2018) 1.4 The waste acceptance rate shall not exceed 1,500,000 tons/yr. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3) Waste acceptance shall be recorded monthly. A new rolling twelve month total of waste acceptance will be determined each month using the previous twelve months data. Records of waste acceptance shall be made available to the Division upon request. 1.5 The reported design capacity of the landfill is 14,147,386 Megagrams (Mg). The facility submitted an amended design capacity report to the Division January 16, 2018 as provided in §60.757(a). An amended design capacity report, along with a permit modification request, if needed, shall be submitted to the Division when there is any change in the design capacity of the landfill. The amended design capacity report shall be submitted within 90 days of any design capacity change approved or recommended for approval to a local jurisdiction by the Colorado Hazardous Materials and Waste Management Division. An increase in design capacity will generally require a permit modification to reflect the increased potential -to -emit of the landfill. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 6 2. C001— Gas Collection and Control System Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission Limits Landfill Gas Combustion 2.1 2.2 Methane Content 2.3 Standards of Performance for Municipal Solid Waste Landfills 2.4 NSPS General Provisions 2.5 National Emission Standards for Hazardous Air Pollutants: MSW Landfills 2.6 PM: 6.7 tons/year PM10: 6.7 tons/year NOx: 39.4 tons/year CO: 197.1 tons/year VOC: 3.6 tons/year SO2: 6.2 tons/year 1576.8 MMscf/year PM: 17 lb/106 dscf methane PM1o: 17 lb/106 dscf methane NOx: 100 lb/106 dscf methane CO: 500 lb/106 dscf methane VOC: AP -42 Ch. 2.4: 98% destruction SO2: AP -42 Ch. 2.4 Recordkeeping & Calculation Recordkeeping Monthly & Annual Monthly & Annual Recordkeeping & Calculation Monthly NSPS Subpart WWW As Defined Subject to NSPS General Provisions MACT Subpart AAAA As Defined 2.1 Emissions of air pollutants shall not exceed the limits listed in Table 2 above. The permit holder shall calculate monthly emissions of PM, PMio, CO, NOR, SO2, and VOC from the control device and keep a compliance record on site for Division review. Compliance with the annual limits shall be determined on a rolling (12) month total using the emission factors from the table and the monthly average results of the methane content determined from the main header. By the end of each month a new twelve month total for PM, PM10, CO, NOR, SO2, and VOC from the control device is calculated based on the previous twelve months' data. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested emissions identified on the APEN submitted on January 16, 2018) The VOC emissions from the control device shall be determined based on the actual measured amount of gas sent to the control device. 2.2 The flare shall be operated at all times when landfill gas is conveyed to the flare with the exception of startup, shutdown, or malfunction. Combustion of landfill gas shall not exceed the limit from the table above. Compliance with the annual consumption limit shall be determined on a rolling twelve (12) month total. Monthly records of the actual consumption rate shall be Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 7 maintained by the applicant and made available to the Division for inspection upon request. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3) 2.3 The methane content of the landfill gas shall be determined monthly. All calculations requiring the use of the methane content shall utilize the monthly average data of readings taken from the main header. The methane content data shall be made available to the Division upon request. 2.4 This source is subject to the Standards of Performance for New Stationary Source requirements of Regulation No. 6, Part A, Subpart WWW (40 CFR Part 60, Subpart WWW), for Municipal Solid Waste Landfills, including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart WWW published in the Federal Register on 10/17/2000. Please note that the state plan for designated facilities under 40 CFR Part 60 Subpart Cf has not been approved by the EPA as of this permit issuance [Date], and is therefore not enforceable. This facility will be subject to Emission Guideline 40 CFR Part 60 Subpart Cf, which will supersede 40 CFR Part 60 Subpart WWW, when EPA approves the state plan for designated facilities as provided in 40 CFR Part 62, Subpart G.] 2.4.1 The landfill shall be equipped with a collection and control system that captures the gas generated within the landfill that meets the design requirements of 40 CFR §60.752(b)(2)(ii)(A). (§60.752(b)(2)(ii)) 2.4.2 Route all the collected gas to an enclosed flare or a treatment system that processes the collected gas for subsequent sale or use. Flare or treatment system shall operate in accordance with a control system designed and operated to reduce NMOC by 98 weight -percent, or, when an enclosed combustion device is used for control, to either reduce NMOC by 98 weight percent or reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen. The reduction efficiency or parts per million by volume shall be established by an initial performance test to be completed no later than 180 days after the initial startup of the approved control system using the test methods specified in §60.754(d); (§60.752(b)(2)(iii)) 2.4.3 The collection and control system may be capped or removed provided that all the following conditions are met: (§60.752(b)(2)(v)) 2.4.3.1 The landfill shall be a closed landfill in which solid waste is no longer placed. A closure report shall be submitted to the Division within 30 days of waste acceptance cessation. No additional wastes may be placed in the landfill without filing a notification of modification as described under 40 CFR §60.7(a)(7). (§60.752(b)(2)(v)(A)) a. When the landfill is closed, the facility is no longer subject to the requirement to maintain an operating permit under 40 CFR part 70 or Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 8 71 for the landfill if the landfill is not otherwise subject to the requirements of either 40 CFR part 70 or 71. (§60.752(d)) 2.4.3.2 The collection and control system shall have been in operation a minimum of 15 years; and (§60.752(b)(2)(v)(B)) 2.4.3.3 The calculated NMOC gas produced by the landfill shall be less than 50 megagrams per year on three successive test dates. The test dates shall be no less than 90 days apart, and no more than 180 days apart. (§60.752(b)(2)(v)(C)) 2.4.4 The gas collection and control system shall be operated as follows: 2.4.4.1 Operate the collection system such that gas is collected from each area, cell, or group of cells in the MSW landfill in which solid waste has been in place for: (§60.753(a)) a. 5 years or more if active; or (§60.753(a)(1)) b. 2 years or more if closed or at final grade; (§60.753(a)(2)) 2.4.4.2 Operate the collection system with negative pressure at each wellhead except under the following conditions: (§60.753(b)) a. A fire or increased well temperature. The owner or operator shall record instances when positive pressure occurs in efforts to avoid a fire. These records shall be submitted with the annual reports as provided in §60.757(f)(1); (§60.753(b)(1)) b. Use of a geomembrane or synthetic cover. The owner or operator shall develop acceptable pressure limits in the design plan; (§60.753(b)(2)) c. A decommissioned well. A well may experience a static positive pressure after shut down to accommodate for declining flows. All design changes shall be approved by the Administrator; (§60.753(b)(3)) 2.4.4.3 Operate each interior wellhead in the collection system with a landfill gas temperature less than 55 °C and with either a nitrogen level less than 20 percent or an oxygen level less than 5 percent. The facility may establish a higher operating temperature, nitrogen, or oxygen value at a particular well. A higher operating value demonstration shall show supporting data that the elevated parameter does not cause fires or significantly inhibit anaerobic decomposition by killing methanogens. The nitrogen and oxygen levels shall be determined as specified in 40 CFR §60.753(c)(1) and (2), respectively. (§60.753(c)) [Please note that the Division approved an oxygen concentration of 10% for wells 39-48 to reduce subsurface methane migration. Exceedances of these standards are not deviations from §60.753(b) & (c) if corrective actions in §60.755(a) are met.] Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 9 2.4.4.4 Operate the collection system so that the methane concentration is less than 500 parts per million above background at the surface of the landfill. To determine if this level is exceeded, the owner or operator shall conduct surface testing around the perimeter of the collection area and along a pattern that traverses the landfill at 30 meter intervals and where visual observations indicate elevated concentrations of landfill gas, such as distressed vegetation and cracks or seeps in the cover. The owner or operator may establish an alternative traversing pattern that ensures equivalent coverage. A surface monitoring design plan shall be developed that includes a topographical map with the monitoring route and the rationale for any site -specific deviations from the 30 meter intervals. Areas with steep slopes or other dangerous areas may be excluded from the surface testing. (§60.753(d)) 2.4.4.5 In the event the collection or control system is inoperable, the gas mover system shall be shut down and all valves in the collection and control system contributing to venting of the gas to the atmosphere shall be closed within 1 hour. (§60.753(e)) 2.4.4.6 If monitoring demonstrates that the operational requirements in Conditions 2.4.4.2, 2.4.4.3, or 2.4.4.4 are not met, corrective action shall be taken as specified in Conditions 2.4.5 or 2.4.7. If corrective actions are taken as specified, the monitored exceedance is not a violation of the operational requirements in this section. (§60.753(g)) 2.4.5 Install a sampling port and a thermometer, other temperature measuring device, or an access port for temperature measurements at each wellhead and: (§60.756(a)) 2.4.5.1 Measure gauge pressure in the gas collection header at each individual well, monthly. If a positive pressure exists, action shall be initiated to correct the exceedance within 5 calendar days, except for the three conditions allowed under Condition 2.4.4.2. If negative pressure cannot be achieved without excess air infiltration within 15 calendar days of the first measurement, the gas collection system shall be expanded to correct the exceedance within 120 days of the initial measurement of positive pressure. Any attempted corrective measure shall not cause exceedances of other operational or performance standards. An alternative timeline for correcting the exceedance may be submitted to the Division for approval. (§60.755(a)(3)) 2.4.5.2 Monitor each well monthly for temperature and nitrogen or oxygen as provided in 2.4.4.3. If a well exceeds one of these operating parameters, action shall be initiated to correct the exceedance within 5 calendar days. If correction of the exceedance cannot be achieved within 15 calendar days of the first measurement, the gas collection system shall be expanded to correct the exceedance within 120 days of the initial exceedance. Any attempted corrective measure shall not cause exceedances of other Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 10 operational or performance standards. An alternative timeline for correcting the exceedance may be submitted to the Division for approval. (§60.755(a)(5)) 2.4.6 The facility shall place each well or design component as specified in the approved design plan. Each well shall be installed no later than 60 days after the date on which the initial solid waste has been in place for a period of: (§60.755(b)) 2.4.6.1 5 years or more if active; or 2.4.6.2 2 years or more if closed or at final grade. 2.4.7 The following procedures shall be used for compliance with the surface methane operational standard as provided in Condition 2.4.4.4: (§60.755(c)) 2.4.7.1 Surface concentrations of methane shall be monitored along the entire perimeter of the collection area and along a pattern that traverses the landfill at 30 meter intervals (or a site -specific established spacing) for each collection area on a quarterly basis using an organic vapor analyzer, flame ionization detector, or other portable monitor meeting the specifications provided in 40 CFR §60.755(d). (§60.755(c)(1)) 2.4.7.2 The background concentration shall be determined by moving the probe inlet upwind and downwind outside the boundary of the landfill at a distance of at least 30 meters from the perimeter wells. (§60.755(c)(2)) 2.4.7.3 Surface emission monitoring shall be performed in accordance with section 4.3.1 of Method 21 of appendix A of 40 CFR part 60, except that the probe inlet shall be placed within 5 to 10 centimeters of the ground. Monitoring shall be performed during typical meteorological conditions. (§60.755(c)(3)) 2.4.7.4 Any reading of 500 parts per million or more above background at any location shall be recorded as a monitored exceedance and the actions specified in paragraphs (c)(4) (i) through (v) of this section shall be taken. As long as the specified actions are taken, the exceedance is not a violation of the operational requirements of Condition 2.4.4.4. (§60.755(c)(4)) a. The location of each monitored exceedance shall be marked and the location recorded. (§60.755(c)(4)(i)) b. Cover maintenance or adjustments to the vacuum of the adjacent wells to increase the gas collection in the vicinity of each exceedance shall be made and the location shall be re -monitored within 10 calendar days of detecting the exceedance. (§60.755(c)(4)(ii)) c. If the re -monitoring of the location shows a second exceedance, additional corrective action shall be taken and the location shall be monitored again within 10 days of the second exceedance. If the re - Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 11 monitoring shows a third exceedance for the same location, the action specified in Condition 2.4.7.4.e shall be taken, and no further monitoring of that location is required until the action specified in Condition 2.4.7.4.e has been taken. (§60.755(c)(4)(iii)) d. Any location that initially showed an exceedance but has a methane concentration less than 500 ppm methane above background at the 10 - day re -monitoring specified in Conditions 2.4.7.4.b or 2.4.7.4.c shall be re -monitored 1 month from the initial exceedance. If the 1 -month remonitoring shows a concentration less than 500 parts per million above background, no further monitoring of that location is required until the next quarterly monitoring period. If the 1 -month remonitoring shows an exceedance, the actions specified in Condition 2.4.7.4.c or 2.4.7.4.e shall be taken. (§60.755(c)(4)(iv)) e. For any location where monitored methane concentration equals or exceeds 500 parts per million above background three times within a quarterly period, a new well or other collection device shall be installed within 120 calendar days of the initial exceedance. An alternative remedy to the exceedance, such as upgrading the blower, header pipes or control device, and a corresponding timeline for installation may be submitted to the Division for approval. (§60.755(c)(4)(v)) f. Any closed landfill that has no monitored exceedances of the operational standard in three consecutive quarterly monitoring periods may skip to annual monitoring. Any methane reading of 500 ppm or more above background detected during the annual monitoring returns the frequency for that landfill to quarterly monitoring. (§60.756(f)) 2.4.7.5 The facility shall implement a program to monitor for cover integrity and implement cover repairs as necessary on a monthly basis. (§60.755(c)(5)) 2.4.8 The provisions of Subpart WWW apply at all times, except during periods of start-up, shutdown, or malfunction, provided that the duration of start-up, shutdown, or malfunction shall not exceed 5 days for collection systems and shall not exceed 1 hour for treatment or control devices. (§60.755(e)) 2.4.9 Install calibrate, maintain, and operate according to the manufacturer's specifications the following equipment: (§60.756(b)) 2.4.9.1 A temperature monitoring device equipped with a continuous recorder and having a minimum accuracy of ±1 percent of the temperature being measured expressed in degrees Celsius or ±0.5 degrees Celsius, whichever is greater. A temperature monitoring device is not required for boilers or process heaters with design heat input capacity equal to or greater than 44 megawatts. (§60.756(b)(1) 2.4.9.2 A device that records flow to or bypass of the control device. The owner Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 12 or operator shall either: (§60.756(b)(2)) a. Install, calibrate, and maintain a gas flow rate measuring device that shall record the flow to the control device at least every 15 minutes; or (§60.756(b)(2)(i)) b. Secure the bypass line valve in the closed position with a car -seal or a lock -and -key type configuration. A visual inspection of the seal or closure mechanism shall be performed at least once every month to ensure that the valve is maintained in the closed position and that the gas flow is not diverted through the bypass line. (§60.756(b)(2)(ii)) 2.4.10 The owner or operator shall submit an equipment removal report to the Division 30 days prior to removal or cessation of operation of the control equipment. (§60.757(e)) 2.4.11 The flare shall be designed for and operated with no visible emission, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. Compliance with this condition shall be monitored by conducting a visible observation of the flare weekly. If visible emissions are present during the weekly observation, a two (2) hour reading shall be performed in accordance with Method 22, the cause of the visible emissions should be determined, and corrective action taken. At least one reading shall be performed in accordance with EPA Method 22 annually. Records of the weekly and Method 22 observations shall be maintained and made available for Division inspection upon request. (§60.18(c)(1) and (0(1)) [Please note that if the flare is not operated during the calendar year, then no weekly opacity observation or annual Method 22 observations are required.] 2.4.12 The flare shall be operated with a flame present at all times. The flare shall be operated at all times when emissions may be vented to it. (§60.18(c)(2) and (e)) 2.4.13 The facility shall submit to the Division annual reports of the recorded information in 40 CFR §60.757(O(1) through (O(6). (§60.757(f)) [Please note that 40 CFR Part 63 Subpart AAAA and Condition 2.6.2 of this section requires reports to be submitted every 6 months] 2.4.14 The facility shall keep the following records: 2.4.14.1 For at least 5 years, up-to-date, readily accessible, on -site records of the design capacity report which triggered §60.752(b), the current amount of solid waste in -place, and the year -by -year waste acceptance rate. Off -site records may be maintained if they are retrievable within 4 hours. Either paper copy or electronic formats are acceptable. (§60.758(a)) 2.4.14.2 For the life of the control equipment, up-to-date, readily accessible records of the data listed in 40 CFR §60.758(b)(1) through (b)(4) as measured during the initial performance test or compliance determination. Records Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 13 of subsequent tests or monitoring shall be maintained for a minimum of 5 years. Records of the control device vendor specifications shall be maintained until removal. (§60.758(b)) 2.4.14.3 For 5 years, up-to-date, readily accessible continuous records of the equipment operating parameters specified to be monitored in §60.756 as well as up-to-date, readily accessible records for periods of operation during which the parameter boundaries established during the most recent performance test are exceeded. (§60.758(c)) 2.4.14.4 For the life of the collection system, an up-to-date, readily accessible plot map showing each existing and planned collector in the system and providing a unique identification location label for each collector. (§60.758(d)) 2.4.14.5 For at least 5 years, up-to-date, readily accessible records of all collection and control system exceedances of the operational standards in Condition 2.4.4, the reading in the subsequent month whether or not the second reading is an exceedance, and the location of each exceedance. (§60.758(e)) 2.5 In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply 2.5.1 At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11) 2.5.2 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§60.12) 2.5.3 Records of startups, shutdowns, and malfunctions shall be maintained, as required under §60.7 2.5.4 Performance tests shall be conducted as required under §60.8 2.5.5 The flare shall be designed and operated, and records and reports shall be furnished, as required under §60.18 Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 14 2.6 This source is subject to the Emissions Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) for Municipal Solid Waste Landfills, including, but not limited to, the following: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart AAAA published in the Federal Register on 01/16/03. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart AAAA.] [Please note that proposed revisions to 40 CFR Part 63 Subpart AAAA were published on 09/08/06. Therefore, the requirements below may change in the future.] 2.6.1 The permittee must develop and implement a written SSM plan according to the provisions in 40 CFR 63.6(e)(3). A copy of the SSM plan must be maintained at the landfill and made available for inspection on request. 2.6.2 The reports described in 40 CFR 60.757(f) must be submitted every 6 months. 2.6.3 The permittee must comply with the general provisions of this part specified in table 1 of this subpart. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: )O(XX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 3. F003 — Fugitive Particulate Matter Emissions Denver Regional Landfill (South) Inc. Page 15 Parameter Permit Condition Number Limitations Monitoring Method Interval PM 3.1 342.5 tons/yr Certification Semi-annually PMio 72.6 tons/yr Fugitive Emissions Control Plan 3.2 Certification Semi-annual 3.1 Particulate Matter (PM and PM10) emissions shall not exceed the limits that are outlined in the table above. The implementation of the Fugitive Emissions Control Plan, in Condition 3.2, serves as a demonstration of compliance with this condition. The owner/operator shall certify semi-annually that the Fugitive Emissions Control Plan is being implemented and followed. (Construction Permit 12W652, as modified under the provisions of Section I, Condition 1.3.) 3.2 The owner/operator shall apply such control measures and operating procedures as are necessary to minimize fugitive particulate emissions (Colorado Regulation No. 1, Section III.D.1.a). The owner/operator shall certify semi-annually that all appropriate measures have been taken to minimize fugitive emissions. The following fugitive emission control measures shall be used for enforcement purposes on the fugitive emission producing sources, as required by Colorado Regulation No.1 (Construction Permit 12WE652). 3.2.1 Adequate soil moisture must be maintained in topsoil and overburden to control emissions during removal. Watering shall be implemented if necessary. 3.2.2 Topsoil and overburden stockpiles shall be compacted and revegetated within one year. 3.2.3 Emissions from material handling (i.e. removal, loading, and hauling) shall be controlled by watering as needed. 3.2.4 Unpaved haul roads shall be watered as often as needed to control fugitive particulate emissions. 3.2.5 All disturbed areas shall be revegetated as needed. 3.2.6 Reclamation works and sequential extraction of material shall be initiated to keep the total disturbed areas at any one time to a minimum. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 SECTION III - Permit Shield Denver Regional Landfill (South) Inc. Page 16 Regulation No. 3, 5 CCR 1001-5, Part C, I.A.4, V.D. & XIII.B; 25-7-114.4(3)(a), C.R.S. 1. Specific Non -Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modifications or reconstruction on which construction commenced prior to permit issuance. No requirements have been specifically identified as non -applicable for this facility. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to §25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Stream -lined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. No applicable requirements were streamlined out of this permit. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 17 SECTION IV - General Permit Conditions ver 5/22/12 1. Administrative Changes Regulation No. 3, 5 CCR 1001-5, Part A, § III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3, Part A, § I.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5, Part C, && III.B.9., V.C.16.a.& e. and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form, report or certification stating that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s) used for determining the compliance status of the source, currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2 && II.A., II.B., II.C., II.E., II.F., II.I, and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving State. b. Emission Monitoring Requirements Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 18 The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 19 d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) - During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 20 e. Circumvention Clause A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan. 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. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement, the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 21 The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration (PSD) increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5, Part C. && III.C.9., V.C.11. & 16.d. and & 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of Regulation No. 3, Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, progress reports which contain the following: (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities, milestones, or compliance were achieved; and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 22 g. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5, Part C, & VII.E An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Part B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S $$ 25-7-114.1(6) and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 23 c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, § III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, §111.D.1. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5, Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3, Part B, without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.11.d. This permit does not convey any property rights of any sort, or any exclusive privilege. 14. Odor Regulation No. 2, 5 CCR 1001-4. Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. 15. Off -Permit Changes to the Source Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 24 Regulation No. 3, 5 CCR 1001-5, Part C, XII.B. The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, t?$ I., H. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II. 17. Open Burning Regulation No. 9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I., II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3, 5 CCR 1001-5, Part C, III.B.6., IV.C., V.C.2. a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, & II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3, 5 CCR 1001-5, Part C, $ V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 25 a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit; or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must specij, that this notification is a deviation report for an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 -month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No. 3, 5 CCR 1001-5, Part A, & II.; Part C, §§ V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (i) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XX.XX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 26 d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No. 3, 5 CCR 1001-5, Part C, & XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years, unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(b)(10) Changes Regulation No. 3, 5 CCR 1001-5, Part C, & XII.A. The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. 25. Severability Clause Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 26. Significant Permit Modifications Denver Regional Landfill (South) Inc. Page 27 Regulation No. 3, 5 CCR 1001-5, Part C, § III.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3, 5 CCR 1001-5, Part C, V.C.1.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CCR 1001-5, Part C. & No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, && III & V. The requirements in paragraphs a, b and e apply to sources located in an ozone non -attainment area or the Denver 1 -hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VIII.C.3. b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RACT) is utilized. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 28 d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored in open containers, or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No. 4, 5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Inspection Information Directions to Plant: Appendix A Page 1 APPENDIX A - Inspection Information The DRLS is located approximately 1.5 miles southeast of Erie, Colorado, at 1441 Weld County Road 6. Access to the landfill is from Interstate 25, Colorado Highways No. 52 and 7, and Weld County Road 5. Safety Equipment Required: Safety Shoes, Hard Hat Facility Plot Plan: Figure 1 (following page) shows the site map as submitted on January 16, 2018 with the source's design capacity report. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. Landscaping and site housekeeping devices equal to or less than ten horsepower in size (Reg. 3, Part C, II.E.3.bb). Individual emission points in attainment areas having uncontrolled actual emissions of any criteria pollutant of less than two tons per year (Reg 3 Part C.II.E.3.a) • Leachate management activities Non -road Engines: (Engines that do not fall under Regulation No. 3 Stationary Source requirements. Non -road engines are not regulated under the stationary source permitting program and, therefore, owners or operators of non - road engines are not required to submit an APEN or obtain an air permit from the Division at this time.) • Air compressor • Power washer • Light plant • Weed eater • Welder Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 2 r- 0 Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 3 Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B Reporting Requirements and Definitions with codes ver 8/20/14 Appendix B Page 1 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B Page 2 For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) (2) (3) A situation where emissions exceed an emission limitation or standard contained in the permit; A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Report #3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B Page 3 to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. 1 For e,gexample, the various emissions limitations and monitoring requirements to which a source may be i subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: X0X 1, 2018 Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Format Page 4 Startup, Shutdown, Malfunctions and Emergencies, Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: xvoc 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format APPENDIX B: Monitoring and Permit Deviation Report - Part I Appendix B Page 5 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Denver Regional Landfill (South) Inc. OPERATING PERMIT NO: 03OPWE254 REPORTING PERIOD: dates) (see first page of the permit for specific reporting period and Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code 2 Malfunction/Emergency Condition Reported During Period? YES NO YES NO F001 Uncollected landfill gas emissions C001 Gas collection and control system F003 Fugitive particulate emissions General Conditions Insignificant Activities ' See previous discussion regarding what is considered to be a deviation. shall be based on a reasonable inquiry using readily available information. 2 Use the following entries, as appropriate 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8=CAM: 9 = Other: Determination of whether or not a deviation has occurred When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: Denver Regional Landfill (South) Inc. OPERATING PERMIT NO: 03OPWE254 REPORTING PERIOD: Appendix B Page 6 Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: (For NSPS/MACT) Did the deviation occur during: Emergency Appendix B Page 7 Malfunction XX N/A Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format APPENDIX B: Monitoring and Permit Deviation Report - Part III Appendix B Page 8 REPORT CERTIFICATION SOURCE NAME: Denver Regional Landfill (South) Inc. FACILITY IDENTIFICATION NUMBER: 1230079 PERMIT NUMBER: 03OPWE254 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 1 APPENDIX C - Required Format for Annual Compliance Certification Reports Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Denver Regional Landfill (South) Inc. OPERATING PERMIT NO: 03OPWE254 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. _ With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determinecompliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Permit Unit ID Unit Description Deviations Reported' Monitoring Method per Permit?2 Was compliance continuous or intermittent?3 Previous Current YES NO Continuous Intermittent F001 Uncollected landfill gas emissions C001 Gas collection and control system F003 Fugitive particulate emissions General Conditions Insignificant Activities 4 If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply. 2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 2 NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility requirements of section 112(r). is is not in compliance with all the 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 181-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 1 APPENDIX D 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-S S -B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Permit Modifications, Off Permit Changes: Office of Partnership and Regulatory Assistance Air and Radiation Programs, 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 1 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP -42 EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD Air Pollution Control Division (State of Colorado) ASTM American Society for Testing and Materials BACT Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in Lbs/mmBtu FR - Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour) LAER - Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf - Million Standard Cubic Feet MMscfd Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PMio - Particulate Matter Under 10 Microns Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 2 PSD - PTE - RACT- SCC - SCF - SIC - SO2 - TPY - TSP - VOC- Prevention of Significant Deterioration Potential To Emit Reasonably Available Control Technology Source Classification Code Standard Cubic Feet Standard Industrial Classification Sulfur Dioxide Tons Per Year Total Suspended Particulate Volatile Organic Compounds Operating Permit 03OPWE254 First Issued: March 1, 2006 Renewed: XXXX 1 2018 Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 1 APPENDIX F Permit Modifications Operating Permit 03OPWE254 First Issued: February 1, 2001 Renewed: XXXX 1, 2017 TECHNICAL REVIEW DOCUMENT DRAFT for RENEWAL of OPERATING PERMIT 03OPWE254 Denver Regional Landfill (South) Inc. Weld County Source ID 123-0079 December 2017 Operating Permit Engineer: Operating Permit Supervisor review: Compliance Unit review: Jayson Ellis Matt S. Burgett Elizabeth Scherer I. Purpose This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit for Denver Regional Landfill (South) Inc. The previous Operating Permit for this facility was issued on March 1, 2006 and expired on March 1, 2011. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the renewal application submitted on March 1, 2010, previous inspection reports and various email correspondence with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at http://www.cdphe.state.co.us/ap/Titlev.html. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating Page 1 permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source Denver Regional Landfill South (DRLS) is classified as a municipal solid waste landfill, which falls under the Standard Industrial Classification 4953. This facility is located at 1441 Weld County Road 6, Erie, Weld County, Colorado. There are no affected states within 50 miles of this facility. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park, and Rawah Wilderness Area. The facility is located in an area designated as attainment for all criteria pollutants, except Ozone. The area became non -attainment for the 8 -hour ozone ambient standard on November 20, 2007. The DRLS is located adjacent to the Denver Regional Landfill North, the Front Range landfill, and the Timberline Energy facility and are considered to be a single stationary source. This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. This facility is categorized as a PSD major stationary source (Potential to emit > 250 Tons/Year for CO). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself (Potential to Emit of > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. The summary of emissions that was presented in the Technical Review Document (TRD) for the original permit issuance has been modified to reflect the most recent emission factors and emission estimates (based on historic waste acceptance rates). Facility -wide emissions are outlined below: Page 2 Landfill VOC 33.0 14.17 CO 3.0 0.0 PM 342.5 0.0 PM10 72.6 0.0 HAPS Total HAP n/a 4.6 Highest n/a 1.6 Single HAP Potential to emit and actual emissions are based on the APENs received on January 16, 2018. Hazardous air pollutant emissions were calculated to show emissions are below major source levels. ill. Applicable Requirements Greenhouse Gasses On July 20, 2011, a final rule regarding biogenic CO2 emission was published in the Federal Register. This final action deferred, for a period of three years, the application of the Prevention of Significant Deterioration (PSD) and Title V permitting requirements to carbon dioxide (CO2) emissions from bioenergy and other biogenic stationary sources (biogenic CO2). As it relates to this facility, biogenic CO2 includes all CO2 generated from the biological decomposition of waste in landfills and CO2 emissions from the combustion of biogas collected from the biological decomposition of waste in landfills. The U.S. Court of Appeals for the D.C. Circuit vacated EPA's "Deferral Rule" for biogenic CO2 emissions on July 12, 2013. After July 20, 2014, biogenic CO2 emissions are now considered for PSD permitting purposes. NSPS Subpart Cf The Environmental Protection Agency announced the reconsideration of certain requirements in the final rules, "Standards of Performance for Municipal Solid Waste Landfills," and "Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills," both published on August 29, 2016. In this action, the EPA is staying subparts, which were added or revised by the two rules, for 90 days pending reconsideration. Title 40 CFR part 60, subpart Cf, and 40 CFR part 60, subpart XXX, are stayed from May 31, 2017 until August 29, 2017. This facility may be subject to the provisions of 40 CFR Part 60 Subpart Cf — Emission Guidelines and Compliance Times for Municipal Solid Waste landfills once EPA approves Colorado's State Implementation Plan. Subpart Cf will replace both the existing Subpart WWW and Subpart Cc. Subpart Cf applies to all existing landfills that have not been expanded or were not newly constructed after July 17, 2014. Subpart Cf includes a new NMOC threshold of 34 Mg/yr to install a gas collection and control system. All Tier 1, 2, and 3 tests remain the same, but the option of a Tier 4 test using site -specific surface methane emissions to show emission controls are not required, will be available after EPA approval of the state's plan. Subpart Cf will apply at all times including at Page 3 startup, shutdown, and malfunction. There will also be changes in wellhead monitoring and electronic reporting to EPA's central data exchange. NSPS Subpart WWW This facility is subject to the provisions of 40 CFR Part 60 Subpart WWW — Standards of Performance for Municipal Solid Waste Landfills, because the landfill was modified on March 1, 2010 and reported a capacity of 13,041,177 Mg. The appropriate requirements are included in the operating permit. DRLS NMOC emission rate is above the NSPS emission threshold of 50 Mg/yr, and is required to operate a gas collection and control system. MACT Subpart AAAA This facility is subject to the provisions of 40 CFR Part 63 Subpart AAAA — National Emissions Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills. The landfill has a design capacity of greater than 2.5 million megagrams and 2.5 million cubic meters, and has an NMOC emission rate above 50 Mg/year. The applicable requirements were included in the permit. Permit Exempt Composting DRLS does not currently have a composting process. AQCC Regulation No. 3, Part B, Section II.D.1.h exempts composting piles from having to obtain a permit. Additionally, Reg. 3 Part C, Section II.E.3.rrr identifies composting piles as an insignificant activity for Title V purposes. However, all applicable odor requirements of Regulation Number 2 must be met and the submittal of APENs is required if emissions exceed the APEN thresholds. This permit exemption does not apply to other activities or emission sources at a composting facility (e.g. grinders, screens, engines). The Division has determined that, in most cases, emissions from compost piles will be fugitive in nature since it is not currently reasonable, nor is it common industry practice, to collect the emissions in order to pass through a stack. This determination is not permanent and could be modified in the future should conditions change. IV. Discussion of Modifications Made Source Requested Modifications • Updated responsible official and contact person for the facility. • Removed all storage tanks and chemical storage containers from permit. The tanks and containers have either been removed or decommissioned. • September 13, 2017 modifications requested o The EPA Method 9 requirement was removed and replaced with the Division approved standard language requiring weekly visible observations in Condition 2.4.11. Page 4 • March 1, 2010 modification request o Section I • Condition 1.1 — Language was updated with suggested wording by the source. • Condition 3.1 — Language was updated to reflect the ozone non -attainment area as requested. The language was also updated to make the permit more consistent with recently issued permits o Section II • Condition 1 — Tables and emissions were updated to the most recent APENs approved by the Division. • The specific flare temperature condition was removed. Condition 2.4.14.3 contains the requirements from NSPS Subpart WWW regarding flare temperature requirements. • Condition 1.1 - Standard Division language was updated and included source suggested language changes. • NSPS Subpart WWW- Language in Condition 1.5 was updated to make the permit more consistent with recently issued permits. This change encompassed the suggested language requested by the source. • Removed Condition 1.6 — The facility did not, and no longer plans to, install a treatment system. • Removed Condition 1.10 — The odor requirements are covered in the General Permit Conditions. • Updated Condition 2.3 — Conditions language was updated to use monthly average methane data. The requirement to determine heat content was also removed. • Condition 3.2.5 — Disturbed areas revegetation requirements were updated to "as needed". o Appendix A • Insignificant actives list was updated as requested. Other Modifications Page 5 In addition to the requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. Page Following Cover Page The monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I - General Activities and Summary • Made revisions to the language in Condition 3 (NANSR/PSD) to be more consistent with other permits. Section II - Specific Permit Terms • Split landfill emissions in to two sections. o Uncollected landfill gas • Updated standard landfill language to the division approved requirements and added petroleum contaminated soil (PCS) requirements. For more information on PCS see PS Memo 12-01. ■ Updated landfill capacity to the most recently submitted Design Capacity Report. o Gas collection and control system ■ Updated NSPS WWW language to current approved division format and requirements. • Landfill fugitive particulate emissions • Removed fugitive emission weekly checks, off property transfer, and vehicle speed limit requirements to be more consistent with recently issued permits. Page 6 Section IV — General Permit Conditions • The language in this section was updated to the most recent version. Appendices • Added scanned plot plan to Appendix A. • Appendix B and C were replaced with latest version. • Updated insignificant actives with source submitted list. Page 7 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT SUMMARY PERMIT NUMBER: 03OPWE254 AIRS ID #: 123-0079 DATE: March 8, 2018 APPLICANT: Denver Regional Landfill (South) Inc. REVIEW ENGINEER: Jayson Ellis SOURCE DESCRIPTION Denver Regional Landfill South (DRLS) is a municipal solid waste landfill and falls under the Standard Industrial Classification 4953. Landfill gas is generated from the decomposition of organic materials found in landfills. Landfill gas is primarily composed of methane and carbon dioxide. Volatile organic compounds (VOC) and hazardous air pollutants (HAP) are present in landfill gas. Landfill gas can be emitted through cover soils but, a portion of the gas is collected and controlled with a landfill gas collection and control system (GCCS). Collected landfill gas is sent to the flare for destruction and/or to a third party facility. During its operation, the flare generates various combustion by-products that are emitted into the atmosphere. Particulate emissions are generated from construction and operation of the landfill, which includes vehicle traffic on paved or unpaved roads, excavation, and the handling of soil cover material. This facility is located at 1441 Weld County Road Six, Erie, Weld County. The area i$ classified as non -attainment for ozone and is part of the 8 -hour Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of this facility. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park, and Rawah Wilderness Area. FACILITY EMISSION SUMMARY Pollutant Potential to Emit (tons/yr) Uncollected Landfill Gas VOC 33.0 CO 3.0 Gas Collection and Control System PM 6.7 PMio 6.7 NOX 39.4 CO 197.1 VOC 3.6 SO2 6.2 Fugitive Particulate Matter PM 342.5 PMio 72.6 Pollutant Actual 2014 (tons/yr) Individual HAPs 1.6 Total HAPs 4.6 EMISSION REVISIONS The following discussion describes the significant revisions that were made to the permit as a result of this renewal. Note that various other minor language changes were made and these are described in the technical review document prepared for this renewal. Flare emissions: NSPS WWW language was updated to the current approved division format. Uncollected landfill gas emissions: The design capacity was updated to reflect form submitted in January of 2018. VOC emissions increased due to this change but, the increase was also based on the divisions current standard for calculation landfill emissions. Petroleum contaminated soil acceptance requirements were also added to the permit. Fuel and Chemical Storage: All storage containers were removed or decommissioned by the facility. INSIGNIFICANT ACTIVITIES A list of insignificant activities is included in the draft Operating Permit. • DENVER. REGIONAL LANDFILL February 25, 2010 Project No. 0601-355-11-13-01 Mr. Jim King Colorado Department of Public Health & Environment Air Pollution Control Division — Stationary Sources Building B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 1441 Weld Co Rd Six P. O. Box 320 Erie, Colorado 80516 Phone (303) 673-9431 Fax (3O3) 673-9432 Re: Operating Permit Minor Modification and Renewal Application Permit Number 03OPWE254 Facility ID: 123/0079 Denver Regional Landfill South — Weld County, Colorado Dear Mr. King: Please find enclosed the Operating Permit Minor Modification and Renewal Application for the Denver Regional Landfill South (facility) located in Weld County, Colorado. The facility currently operates under Permit Number 03OPWE254, which was issued March 1, 2006 and last revised February 1, 2008. Relevant Title V Application Forms are provided in Attachment 1. The requested revisions are discussed in detail in Attachment 2. The proposed modifications meet the minor modification criteria, and as such, the site requests the Division to process this modification application under AQCC Regulation No. 3. Part C, Section X. As specified in Colorado Regulation 3, Part C, Section X.I, it is our understanding that the site will be allowed to make the changes proposed in the application for a minor permit modification immediately after the application is filed. In accordance with Colorado Air Quality Control Commission (AQCC) Regulation No. 3 Part C, Section X.D.6, the revised APEN has been provided in Attachment 3. The LandGEM v3.02 Model and emission calculations supporting the revised APEN are included as Attachment 4 and Attachment 5, respectively. A suggested draft permit is included as Attachment 6 for the revised sections of the permit including the information page, Section I, Section II, and Appendix A. In conjunction with minor modifications to the operating permit, please update the site's construction permit. C: IDOC UMENTS AND SETTINGSUEFFBUILOCAL SETTINGSITEMPORARY INTERNET FILESIOLK]I LTR-CDPHE (TO BE PRINTED ON WCI LETTERH£AD).DOC 4 - Jim King February 25, 2010 Page 2 In addition to the operating permit minor modification, please renew Operating Permit 03OPWE254. The Title V Application Forms address the renewal as well as the minor modification. This renewal application has been prepared and submitted pursuant to the Colorado Air Quality Control Commission Regulation No. 3. Part C, Section III.B.6. One original and three copies of this application are provided for your use and distribution. A copy of this submittal has been placed in the site operating record for this facility. If you need any additional information or have any questions during the course of your review, please feel free to call me or Matt Stutz of Weaver Boos Consultants at 817- 735-9770. Sincerely, Waste nections, Inc. Jeff furrier District Manager Attachments: Attachment 1 — Title V Application Forms Attachment 2 — Minor Modifications Revisions Attachment 3 — Revised APEN Attachment 4 — LandGEM v3.02 Model Attachment 5 — Emission Calculations Attachment 6 — Suggested Draft Permit APEN Fees (Check for $152.90) cc: Office of Partnerships and Regulatory Assistance, U.S. E.P.A., Region VIII Matt Stutz, P.E., Weaver Boos Consultants John Briest, P.E., Weaver Boos Consultants C:IDOCUMENTSAND SETTINGSVEFFBUILOCAL SETT/NGStTEMPORARYINTERNET FILESIOLK?ILTR-CDPHE (TO BE PRINTED ON WCI LETTERHEAD).D0C ATTACHMENT 1 TITLE V APPLICATION FORMS FACILITY IDENTIFICATION (FORM 2000-100) Operating Permit Application FACILITY IDENTIFICATION Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and Name mailing address Street or Route City, State, Zip Code Denver Regional Landfill (South) P.O. Box 320 Erie, CO 80516 2. Facility location Street Address 1441 Weld County Road Six (No P.O. Box) City,County, Zip Code Erie, CO 80516 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) Denver Regional Landfill (South), Inc. P.O. Box 320 Erie, CO 80516 4. Responsible official Name Title Telephone Jeff Burlier District Manager (303) 968-9508 5. Permit contact person Name Title (If Different than 4) Telephone 6. Facility SIC code: 4953 8. Federal Tax I. D. Number: 930923492 Jeff Burlier District Manager (303) 968-9508 7. Facility identification code: CO 1230079 9. Primary activity of the operating establishment: Municipal Solid Waste Disposal 10. Type of operating permit New X Modified 11. Is the facility located in a "nonattainment" area: X Yes No If "Yes", check the designated "non -attainment" pollutant(s): Carbon Monoxide X Ozone X Renewal PM10 Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. Construction Permit No. 12WE652 O: \WASTE CONNECTIONSDENVER REGIONAL-S'OOTH`TITLE. NMINOR MOD 20I01FAC'ILITY ID FORM 2000-I00.DOC 1 FACILITY IDENTIFICATION -- Form 2000-100 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Use "NA" where necessary to identify an information request that does not apply. One form should be included with each application. Item 1 Provide full business name and address of corporation, company, association, society, firm, partnership, individual or political subdivision of the state submitting the application. Item 2 Street address where the air pollution sources are or will be located. For remote locations, land plat descriptions (Township, Range, Section, Subsection location) are acceptable. Item 3 If wholly or partly owned by another entity, identify that entity. Item 4 The responsible official is a person legally responsible for the operation of the permitted air pollution sources. For a corporation, this person must be the president, vice-president, secretary or treasurer, or other person with a similar level of responsibility in the company. Prior to filing the application, if you want the Division to approve your choice of responsible official you may send a letter to the Division describing that person's authority in the company and requesting the Division's approval. Item 5 Individual to contact during the permitting process for additional information concerning the air pollution sources. Item 6 The primary Standard Industrial Classification (SIC) code for the facility where the source(s) are located. Item 7 Provide the facility identification (FID) code. The Division has assigned a unique code to your facility. The code begins with "CO" (Colorado) and has 7 digits. Item 8 Provide the Facility Federal Tax Number. This is a nine -digit number. Item 9 Provide a short statement about your facility's activities such as "lead -acid battery manufacture" or "sulfite paper mill." Item 10 Indicate the type of permit application being submitted. An applicant may at any time request an operating permit that is otherwise not required. Item 11 Indicate whether the facility is located in a nonattainment areaeven if your facility does not emit the pollutant. Please refer to the instruction booklet and Appendix G of the instruction book. If the area is attainment for all pollutants, enter "Attainment for all Pollutants". Item 12 Identify all facility air pollution permits, plan approvals (fugitive dust), and exemptions issued by U.S. EPA or Colorado APCD that are still in effect. Include grandfathered emission units. Please do not list old permits, exemptions, etc. that have expired or been superseded by more recent approvals. List the permit number, date, and unit or operation covered by the permit. Example: 88DE189 May 15, 1989 Fugitive Dust Sept 1, 1992 Grandfathered Feb 2, 1972 Incinerator Gravel Pit Smith Boiler O.: iWASTE C:ONNECTIONS,DENVER REGIONAL-SOU7H.T%T LE V:MINOR MOD 20I0EF42ILI7Y ID FORM 2000-100.DOC 2 INSIGNIFICANT ACTIVITIES (FORM 2000-102B AND FORM 2000-700) OperatingrPermit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and Environment Air Pollution Control Division FORM 2000-102B Rev 06-95 Facility Name: Denver Regional Landfill (South) Facility Identification Code: CO 1 2 3 0 0 7 9 NOTE: The operating permit must be prepared and submitted on thrms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating permit application.The Division will not consider or act upon your application unless each form used has been entirely completed. Certain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's emissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the facility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. ❑ (a) noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non -criteria reportable pollutant. ❑ Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). ❑ Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). ❑ Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 500 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. ❑ Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. IN Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). ❑ Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. ❑ Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. ❑ Oil production wastewater (produced water tanks), containing less than 1% by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. (Continues on other side) 1 • Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. 0 Storage tanks of capacity < 40,000 gallons of lubricating oils. 0 Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. ■ Fuel storage and dispensing equipment in ozone attainment areas operated solely for company -owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 -day period. 0 Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. ■ Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). O Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. O Stationary Internal Combustion Engines which: (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii) have actual emissions less than five tons per year or rated horsepower of less than 50. ❑ Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. • Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY 2 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SUPPLEMENTAL INFORMATION FORM 2000-700 09-94 SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Denver Regional Landfill (South) 2. Facility identification code: CO 1230079 3. This form supplements Form 2000 - 102B for Emission Unit (e.g. B001, P001, etc.) Additional Information, Diagrams Item Number • (1) 6,000 gal AST off -road fuel • (1) 270 gal AST on -road fuel • (1) 1,000 gal UST gasoline • (1) 5,000 gal portable AST off -road fuel • Miscellaneous routine vehicle and site maintenance materials stored in drums and containers • Leachate and condensate management activities • (1) Air compressor, 120 hp • (1) Power washer, 16 hp • (1) Light plant, 10.7 hp • (1) Weed eater, 22.8 cc • (1) Welder, 624 cc 0: iWaste Coimectons Denver Regional-.Southl'Title G'Minor Mod 20101 Supplemental b fo 2000-700.doc 1 RESPONSIBLE OFFICIAL CERTIFICATION (FORM 2000-800) Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Denver Regional Landfill (South) I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code: CO 1230079 This application contains the following forms: X Form 2000-100, Facility Identification ❑ Form 2000-101, Facility Plot Plan X Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing O Form 2000-200, Stack Identification ❑ Form 2000-300, Boiler or Furnace Operation ❑ Form 2000-301, Storage Tanks ❑ Form 2000-302, Internal Combustion Engine ❑ Form 2000-303, Incineration ❑ Form 2000-304, Printing Operations ❑ Form 2000-305, Painting and Coating Operations ❑ Form 2000-306, Miscellaneous Processes ❑ Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: D Form 2000-400, Miscellaneous ❑ Form 2000-401, Condensers O Form 2000-402, Adsorbers ❑ Form 2000-403, Catalytic or Thermal Oxidation ❑ Form 2000-404, Cyclones/Settling Chambers ❑ Form 2000-405, Electrostatic Precipitators ❑ Form 2000-406, Wet Collection Systems ❑ Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, O Form 2000-500, Compliance Certification - Monitoring and Reporting ❑ Form 2000-501, Continuous Emission Monitoring ❑ Form 2000-502, Periodic Emission Monitoring Using Portable Monitors ❑ Form 2000-503, Control System Parameters or Operation Parameters of a Process ❑ Form 2000-504, Monitoring Maintenance Procedures ❑ Form 2000-505, Stack Testing ❑ Form 2000-506, Fuel Sampling and Analysis ❑ Form 2000-507, Recordkeeping ❑ Form 2000-508, Other Methods 0:WASTE CONNECT/ONSIDENVER REGIONAL-SOU7H' TITLE ("MINOR MOD 201080 CERT FORM 2000-800.DOC 1 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan O Form 2000-600, Emission Unit Hazardous Air Pollutants ❑ Form 2000-601, Emission Unit Criteria Air Pollutants O Form 2000-602, Facility Hazardous Air Pollutants O Form 2000-603, Facility Criteria Air Pollutants ❑ Form 2000-604, Applicable Requirements and Status of Emission Unit o Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule O Form 2000-607, Plant -Wide Applicable Requirements O Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE X I certify that the facility described in this air pollution permit application requirements. O I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes or certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Jeff Burner Title District Manager ' ature Date Signed aILrIto/6 i P: ILFGIPROJEC7SINASTE CONNECTIONSIDENVER REGIONAL SOUTHITITLE VIM INOR MOD 201080 CERT FORM ?000-80O.DOC' 2 v Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Denver Regional Landfill (South) Facility Identification Code: CO 1230079 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT I have the statements B. CERTIFICATION X ❑ WARNING: Any or certification accordance with OF COMPLETENESS reviewed this application in its entirety and, based on information and belief and information contained in this application are true, accurate and OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY I certify that the facility described in this air pollution permit application requirements. I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in (list all non -complying units) person who knowingly, as defined in § 18-1-501(6), C.R.S., makes in, or omits material information from this application is guilty of a the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Jeff Burner Title District Manager Si re \� _ Date Signed Z2f-17_,DtD SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 P ILFGIPROJECTSIWAST E CONNECTIONSIDENVER REGIONAL SOU?NI TITLE NMINOR MOD 20/0V2O CERT FORM 2000-800.DOC 3 ATTACHMENT 2 MINOR MODIFICATION REVISIONS MINOR MODIFICATION REVISIONS Cover Page As indicated in Attachment 6 (Suggested Draft Permit) and shown below, please update the Responsible Official and Facility Contact Person information. Responsible Official: Jeff Burlier District Manager 1441 Weld County Road 6 Erie, CO 80516 (303) 968-9508 Facility Contact Person: Jeff Burlier District Manager 1441 Weld County Road 6 Erie, CO 80516 (303) 968-9508 The current Responsible Official information was submitted to CDPHE, and written approval from CDPHE was received dated August 19, 2009. Section I — General Activities and Summary 1. Permitted Activities, Condition 1.1 Please revise the text in the first and second paragraphs as proposed in Attachment 6 (Suggested Draft Permit). The permit condition refers to the "GMCS," landfill gas migration control system. A "GCCS," landfill gas collection and control system is a more accurate description and will provide for consistency between permit and NSPS language. Additionally, the site did not, and no longer plans to, install the dewatering treatment system or transport LFG to a pipeline for sale, so please remove all references to the dewatering treatment system and sale of LFG. The site may route LFG to an energy facility owned and operated by an independent third party. The energy facility will be permitted separately from Denver Regional Landfill (South). In the second paragraph please update the text to identify the 8 -hour ozone nonattainment designation for the area. Weaver Boos Consultants, LLC—Southwest O:',WASTE CONNEC77ONSiDENVER REGIONAL-SOU7HITITLE VIMINOR MOD 2OIOiL7R-CDPHE.DOC 2/26/2010 3. Prevention of Serious Deterioration (PSD), Condition 3.1 Please update the first paragraph to reflect the 8 -hour ozone nonattainment designation for the area. Suggested text for this condition is included with Attachment 6 (Suggested Draft Permit). 6. Summary of Emission Units, Condition 6.1 Please revise the emission units table as shown in Attachment 6 (Suggested Draft Permit). The flare is the only emission source which can be considered pollution control equipment, and the reference to the "Treatment System" can be removed. Section II — Specific Permit Terms Condition 1. F001 & C001 — Landfill Gas Emissions & Flare Table The site requests that the Division revise the table under Condition 1 as indicated in Attachment 6 (Suggested Draft Permit) and explained below. Please update the long term emission limitations and compliance emission factors to reflect the revised APEN in Attachment 3 and the emission calculations in Attachment 5. As the site continues to accept waste, landfill gas generation increases, and as such, this revision is requested to update the permit to reflect the current conditions for potential emissions. Please remove all reference to "Treatment System Periodic Monitoring." The site did not, and no longer plans to, install the treatment system. Please revise the temperature listed under the Flare destruction efficiency parameter to 1065.6° F. The listed temperature represents the average flare temperature of 1116° F during the most recent stack test. However, 40 CFR §60.758(c)(1)(i) requires the facility to report any 3 -hour or more period of time during which the flare operates 28° C below the performance test temperature. In order to be consistent with NSPS WWW, please revise the listed temperature to reflect the actual minimum operating temperature required by NSPS WWW or 1065.6° F which is 1116° F minus 50.4° F (difference of 28° C). Please revise the "Heat (BTU) & methane content of landfill gas" parameter to only include the methane content. With the updated emission factors, the heating value of the landfill gas is not relevant to calculating emissions, and therefore, should not require monitoring. Please revise the monitoring interval to monthly as discussed with the requested revisions for Condition 1.11. Weaver Boos Consultants, LLC—Southwest O: WASTE CONNECTIONSIDENVERREGIONAL-SOUTHITITLEV!MINORMOD20IOILTR-CDPHE.DOC 2/26/2010 Condition 1.1 Please revise the second and third sentences of the Condition 1.1 as exemplified in Attachment 6 (Suggested Draft Permit). The second sentence refers to the calculation of landfill gas emissions, but there are no limits associated with emissions of landfill gas. It is our understanding that the emission limits associated with Condition 1.1 only apply to VOC emissions from the flare and as fugitive emissions. The third sentence of Condition 1.1 states that VOC emissions are a set portion of the NMOC emissions. Since the site is controlled according to NSPS WWW requirements, the site is no longer required to calculate NMOC emissions. Therefore, please revise this condition to base the VOC concentration as a set portion of the NMOC concentration of landfill gas. Basing the emissions on NMOC concentration will eliminate the unnecessary burden of calculating NMOC emissions and simplify compliance demonstration calculations. Condition 1.4 Please update Condition 1.4 as indicated in Attachment 6 (Suggested Draft Permit). The listed temperature represents the average flare temperature of 1116° F during the most recent stack test. However, 40 CFR §60.758(c)(1)(i) requires the facility to report any 3 - hour or more period of time during which the flare operates 28° C below the performance test temperature. In order to be consistent with NSPS WWW, please revise the listed temperature to reflect the actual minimum operating temperature required by NSPS WWW or 1065.6° F which is 1116° F minus 50.4° F (difference of 28° C). Condition 1.5.3 Please update Condition 1.5.3 as suggested in Attachment 6 (Suggested Draft Permit). NSPS WWW allows for any one of three options regarding the control of landfill gas. In order to keep the permit requirements consistent with NSPS WWW requirements, please revise Condition 1.5.3 to include the other two options for controlling landfill gas. Condition 1.5.8 Please update Condition 1.5.8 as suggested in Attachment 6 (Suggested Draft Permit). The GCCS plan is routinely revised as a landfill accepts waste and ages. In order to avoid confusion and repetitive revisions, the site suggests removing the reference to the specific date of the most recent GCCS plan approval and only referencing the applicable GCCS plan as the "most recently approved" version. Weaver Boos Consultants, LLC-Southwest O:'WASTE CONNECTIONS''DEN ER REGIONAL-SOUTIPTITLE NMINOR MOD 20IOIL7R-CDPHEDOC 2/26/2010 Condition 1.6 Please remove the Condition 1.6 as indicated in Attachment 6 (Suggested Draft Permit). The site did not, and no longer plans to, install the treatment system Condition 1.7.3 As proposed in Attachment 6 (Suggested Draft Permit), please remove Condition 1.7.3 which is no longer applicable to Denver Regional Landfill South. The site is an existing facility with ongoing operations, and as such, the initial startup and construction notification will not apply. Condition 1.11 Please revise Condition 1.11 as suggested in Attachment 6 (Suggested Draft Permit) and explained below. As discussed with Condition 1. revisions, the proposed landfill gas combustion emission factors and limitations are in terms of cubic feet of landfill gas or methane combusted. As proposed, all calculation methodologies and limitations will be independent of heat content, and any heat content determination of the landfill gas would be irrelevant. Therefore, the site requests the Division to remove heating value analyses from Condition 1.11. In addition, the site requests the option to use the monthly methane average data instead of the methane content analytical results in order to more accurately determine emissions. Given the nature of methane fluctuations that occur in landfill gas, monthly readings taken in the field are more accurate for estimating emissions than a one-time analysis applied for a six-month period. Condition 2.4.4 It is requested that the speed limit be revised to 25 mph as shown in Attachment 6 (Suggested Draft Permit). EPA's AP -42, Section 13.2.2, Equation la was used to calculate the particulate emissions from vehicles traveling on unpaved industrial roads at this site. Table 13.2.2-3 contains the range of conditions within which Equation la remains an accurate emission calculation tool. The equation accurately calculates emissions for vehicles traveling between 5 and 43 mph; therefore, the current particulate emission calculations should be valid for vehicles traveling up to 43 mph. As such, the site requests that the maximum speed for vehicles on unpaved roads be revised to a maximum of 25 mph. Weaver Boos Consultants, LLC—Southwest O: WASTE CONNECTIONSIDENVERREGIONAL-SOUTH: TITLE NM/NOR MOD 20I0LTR-CDPHE.DOC 2/26/2010 s Condition 2.4.6 Please revise Condition 2.4.6 as indicated in Attachment 6 (Suggested Draft Permit). It is unclear what information the permit condition is referring to, and the site requests that the reference be replaced with "as needed" to allow the site the option of revegetating as the need arises. Appendix A — Inspection Information List of Insignificant Activities: Please revise the appendix to reflect the 8 -hour ozone nonattainment designation for the southern portion of Weld County and the updated insignificant sources/activities provided with CDPHE Form 2000-102B and 2000-700. The requested revisions are included with Attachment 6, the Suggested Draft Permit. Weaver Boos Consultants, LLC—Southwest O:'WASTE CONNECTIONSIDENVER REGIONAL-SOUTNTITLE VMINOR MOD 2010kLTRCDPHEDOC 2/26/2010 ATTACHMENT 3 REVISED APEN • AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 03OPWE254 [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 0079 / 007 Facility Equipment ID: LFG Flare and Fugitives [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01— Administrative Information Section 02 — Requested Action (check applicable request boxes) Company Name: Denver Regional Landfill (South) Inc. Source Name: Denver Regional Landfill (South) Source Location: 1441 Weld County Road Six Portable Source Home Base: Erie, Colorado Mailing Address: 1441 Weld County Road Six Erie, Colorado Person To Contact: Jeff Burlier E-mail Address: jeffbu@wcnx.org Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: NAICS, or SIC Code: 4953 County: Weld Elevation: 5188 Feet ZIP Code: 80516 Phone Number: 303-968-9508 Fax Number: / / 1980 ❑ Request for NEW permit or newly reported emission source ❑ Request PORTABLE source permit ® Request MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name ® Change permit limit ❑ Transfer of ownership ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) O Revision to actual calendar year emissions for emission inventory ❑ Other Update 5 -Year APEN term without change to permit limits or previously reported emissions Additional The AIRS ID 1230079/007 and this APEN include emissions information Info. & for Emission Unit Numbers F001 and C001. Notes: For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/week 52 weeks/year Landfill Gas Flare and Landfill Gas Fugitive Emissions / / Will this equipment be operated in any NAAQS nonattainment area? (http://www.cdphe.state.co.us/aWattainmaintain.html) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment': Manufacturer: Model No.: ® Yes ❑ No ❑ Serial No.: Don't know eseri 0 ata ear) tied Lei ess`. its/I- .our: 'If additional space is required, please attach a separate list of equipment, materials and throughputs. 'Requested values will become permit limitations. Requested level should consider process growth over the next five years. FORM APCD-200 Page 1 of 3 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 to: Colorado Department of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://www.cdphe.state.co.us/ap/downloadfornts.httml Application status: http://www.cdphe.state.co.us/ap/ss/ssocpt.html ® Check box to request copy of draft permit prior to issuance. ❑ Check box to request copy of draft permit prior to public notice. GeneralAPEN • TSP AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 03OPWE254 Emission Source AIRS ID: 123 / 0079 / 007 Section 05 — Emission Release Information (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) . rglor 1' - St 13ase'� dn, .:� t) .,a ,,Dtscluu• e)Iet ht, g.. g ba @. + � A ^ Gtr d �-� ..�� Totn P �.: _��• r Flo RaeVpl x . • iY ) �-� :; :, ct P IY.,t ft/ e li,g, � `� ois r e Y'•' /;, y<,t.040 �. of zontall?aum �xw"!, , E _. , „ `9a 4)• �, �� 1� 'r trlEasi�n ter .. $ �, �o ifud �. Me : , r t� �{ R iX, a ) P. t d 'a...tu lit kl1tJ .af"Cull 1 fO `'" c 1 e t 1 t` a at..... , .. C001 5,188 40 1,116 45,700 480 8% 84 13 497667.31 4430985.54 Google Earth rection of outlet (check one): ® Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: Manufacturer: Power Strategies ❑ Horizontal ❑ Down ❑ Other: Length (inches) _ ❑ Other (Describe): Width (inches) = Model: Cleanair Flare EF-90 Serial No.: �� Dt t t. n` ut_Aate : gt'• '' 10 Btu/hr `� :_:. ) �= _,-Actual; 'evel For t`lata;Year ( ) t e A tnual ) t d_Perlmtte :Le 9. . ,,Ye. d .:, ,S b i U ts' �i1 �fy:.4� ) ,.l uel.: e8 dal R, g ndtcate t 'w Btupb Ii al'- . =,,",F , �.,.ttdg ��).. Per' t esnby Welltt 1 %- ? SBaSiirialuel, IJSe o ^. % of tinual •. tlse : „, �u≥�ktt..r. r '.'Ashy ..pet�lteb awMay 4.itltwAvpi �.$u.0-Nnv� Landfill Gas 90 Max 1576.8 MMscf 500 Btu/scf at 50% Methane 25 25 25 25 ions. Requested level should consider process growth over the next five years. Section 07 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. El Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): I vice scrll Flare 17 A 'S lb/MMscf Methane lb/MMscf Methane eari atrSl)e nsll Y'Yea ana ism1011.i trolled KY.6ar) =' 6.7 AP -42 PMto Flare 17 6.7 AP -42 PIN/12.5 SOx Flare 6.0 AP -42 NOx Flare 100 lb/MMscf Methane 39.4 AP -42 VOC Flare 98% 34.7 AP -42 CO Flare 500 lb/MMscf Methane 197.1 AP -42 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 3 Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions. Page 2 of 3 GeneralAPEN AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. ction 08 —Ann t Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. rs.. Le'ail thorizedto°Supply. `"'tI:...,. -- L1 Jeff Burlier District Manager arne v egaltit44 a 90,m4? F ran 4 y 4102 Page 3 of 3 GeneralAPEN NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: Company Name: Plant Location: Person to Contact: E-mail Address: 03OPWE254 Denver Regional Landfill (South), Inc. 1441 Weld County Rd. 6 Jeff Burlier jeffbu@wcnx.org AIRS ID Number: 123/0079/007 County: Weld Phone Number: 303-968-9508 Fax Number: Zip Code: 80516 Chemical Abstract Service (CAS) Number Chemical NameIN ReportingControl Equipment / Reduction (%) Emission Factor (Include Units) Emission Factor Source Uncontrolled Actual Emissions (lbs/year) Controlled Actual Emissions (lbs/year) 79-34-5 1,1,2,2 — Tetrachloroethane A Attachment 5 625.1 75-34-3 1,1 — Dichloroethane B Attachment 5 804.2 75-35-4 1,1 - Dlchloroethene A Attachment 5 65.6 107-06-2 1,2 — Dichloroethane A Attachment 5 137.4 78-87-5 1,2 — Dichloropropane A Attachment 5 68.9 107-13-1 Acrylonitrile A Attachment 5 1,137.2 71-43-2 Benzene A Attachment 5 502.5 75-15-0 Carbon Disulfide A Attachment 5 149.5 108-90-7 Chlorobenzene A Attachment 5 95.3 74-87-3 Chloromethane A Attachment 5 205.1 106-46-7 Dichlorobeznene A Attachment 5 104.5 75-09-2 Dichloromethane A Attachment 5 4,112.4 75-18-3 Dimethyl Sulfide C Attachment 5 1,640.8 100-41-4 Ethyl Benzene C Attachment 5 1,653.4 110-54-3 Hexane C Attachment 5 1,925.8 7783-06-4 Hydrogen Sulfide A Attachment 5 4,096.2 108-10-1 Methyl Isobutyl Ketone B Attachment 5 644.3 74-93-1 Methyl Mercaptan A Attachment 5 407.2 127-18-4 Perchloroethylene A Attachment 5 2,094.2 108-88-3 Toluene C Attachment 5 12,165.1 79-01-6 Trichloroethylene C Attachment 5 1,245.7 75-01-4 Vinyl Chloride A Attachment 5 1,553.2 1330-20-7 Xylenes C Attachment 5 4,313.1 7647-01-0 Hydrogen Chloride A Attachment 5 6,166.6 75-71-8 Dichlorodifluoromethane C Attachment 5 6,427.1 Reporting Scenario (1, 2 or 3): 1 Form Revision Date: December 4, 2006 Calendar Year for which Actual Data Applies: Potential -To -Emit 2+g )o( Signatu a •f Fierson Legally Authorized to Supply Data Jeff Burlier r/Le/D Dat District Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data GUIDANCE FOR NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM Non -Criteria Reportable Air Pollutant Emission Notice Addendum: This form should be completed to report emissions of Hazardous Air Pollutants (HAP) and other non -criteria reportable pollutants listed in Regulation 3, Part A, Appendix B. Permit Number: For New Permit Applications leave this blank. For modifications to existing permits, please list the permit number previously issued by the APCD. AIRS ID Number: For New Permit Applications leave this blank. For modifications to existing permits, please list the emissions point AIRS ID number previously issued by the APCD. Chemical Abstract Service (CAS) Number and Chemical Name: Please list the CAS number and common chemical name for each non -criteria reportable air pollutant that is emitted from this emission point. A list of CAS numbers and common chemical names may be found in Regulation 3, Appendix B. Reporting BIN: Please list the reporting BIN for each non -criteria reportable pollutant reported. The reporting BIN may be determined by reviewing Regulation 3, Appendix B. Reporting Scenario: The reporting scenario is established by evaluating the release point of the emission unit and the proximity of the property boundary closest to the release point according to the definitions and scenarios described below. Further details on how to determine the appropriate reporting scenario are contained in Regulation 3, Appendix A. The Division will assume scenario "1" if this information is left blank. Otherwise, an operator may choose scenario "1" by default or evaluate the reporting scenario based on the following definitions: Release Point: the lowest height above ground level from which the pollutants are emitted to the atmosphere. Property Boundary: the distance from the base of the release point to the nearest property boundary. Point: an individual emission point or a group of individual emission points reported on one Air Pollutant Emission Notice as provided for in Part A, section II.B.4. Scenario 1: Release point less than 10 meters (— 33 feet) or property boundary less than 100 meters (— 328 feet); Scenario 2: Release point equal to or greater than 10 meters (— 33 feet), but less than 50 meters (— 164 feet), or property boundary equal to or greater than 100 meters (' 328 feet), but less than 500 meters (- 1,640 feet); or Scenario 3: Release point equal to or greater than 50 meters (— 164 feet), or property boundary equal to or greater than 500 meters (— 1,640 feet). Control Equipment / Reduction (%): Please list the type of control equipment used (i.e. SCR, NSCR, Flare, Thermal Oxidizer, etc.) and report the minimum percent reduction achieved by the control equipment. Emission Factor: Please list the emission factor used to calculate the emission rates listed in the actual emission columns. Fill this information out if the applicant has calculated emissions in lieu of having the Air Pollution Control Division (APCD) calculate the emissions for the company. Emission Factor Source: Example emission factor sources include: AP -42, GRI HAP Calc., EPA TANKS, GRI GLY Calc., Manufacturer's Emission Factor, and Mass Balance. Uncontrolled Actual Emissions: Enter the actual uncontrolled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point excluding any emission reduction achieved by control equipment. Form Revision Date: December 4. 2006 Controlled Actual Emissions: Enter the actual controlled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point including the emission reduction listed in the "Control Equipment Reduction (%)" column. Enter "N/A" if the emissions are uncontrolled. SUBMITTAL OF THIS ADDENDUM MUST BE ACCOMPANIED BY AN AIR POLLUTANT EMISSION NOTICE (APEN) Copies of this form may be obtained on the Internet at the following URL: http://www.cdphe.state.co.us/ap/downloadforms.html Form Revision Date: December 4. 2006 ATTACHMENT 4 LANDGEM V3.02 MODEL Landgem- DRLS-Jan.2010 2/15/2010 Summary Report andGE any iii was Err)issions C~ iodei ersr ri 3.02 .. LT.S. E :> rotunen a1 Protection vfiice of t e s; and Deve aprrm r± 1_h I<1ar_arzm nt _esearch Laboratory . (NRI„, ,J_, TechneloF, Center(CATC} Rnsea r_1 T'-taagIe Parks,1do tCY L Landfill Name or Identifier: Denver Regional Landfill South Date: Monday, February 15, 2010 Description/Comments: C&D waste is considered inert and is not accounted for in the model input waste acceptance. About LandGEM: First -Order Decomposition Rate Equation: 1;4 Where, i=1 1=0.1 QcH4 = annual methane generation in the year of the calculation (m 3/year) i= 1 -year time increment n = (year of the calculation) - (initial year of waste acceptance) j = 0.1 -year time increment k = methane generation rate (year -1) Lo = potential methane generation capacity (m 3/Mg) M; = mass of waste accepted in the ith year (Mg) ti = age of the jth section of waste mass M, accepted in the it" year (decimal years, e.g., 3.2 years) LandGEM is based on a first -order decomposition rate equation for quantifying emissions from the decomposition of landfilled waste in municipal solid waste (MSW) landfills. The software provides a relatively simple approach to estimating landfill gas emissions. Model defaults are based on empirical data from U.S. landfills. Field test data can also be used in place of model defaults when available. Further guidance on EPA test methods, Clean Air Act (CAA) regulations, and other guidance regarding landfill gas emissions and control technology requirements can be found at http://www.epa.gov/ttnatw0l/landfill/IandflFy.html. LandGEM is considered a screening too(— the better the input data, the better the estimates. Often, there are limitations with the available data regarding waste quantity and composition, variation in design and operating practices over time, and changes occurring over time that impact the emissions potential. Changes to landfill operation, such as operating under wet conditions through leachate recirculation or other liquid additions, will result in generating more gas at a faster rate. Defaults for estimating emissions for this type of operation are being developed to include in LandGEM along with defaults for convential landfills (no leachate or liquid additions) for developing emission inventories and determining CAA applicability. Refer to the Web site identified above for future updates. REPORT -1 Landgem- DRLS-Jan.2010 2/15/2010 Input Review LANDFILL CHARACTERISTICS Landfill Open Year Landfill Closure Year (with 80 -year limit) Actual Closure Year (without limit) Have Model Calculate Closure Year? Waste Design Capacity MODEL PARAMETERS Methane Generation Rate, k Potential Methane Generation Capacity, L, NMOC Concentration Methane Content GASES/POLLUTANTS SELECTED Gas / Pollutant #1: Total landfill gas Gas / Pollutant #2: Methane Gas / Pollutant #3: Gas / Pollutant #4: WASTE ACCEPTANCE RATES 1980 2011 2011 No short tons 0.020 year1 100 m3/Mg 595 ppmv as hexane 50 % by volume Year Waste Accepted Waste -In -Place (Mg/year) (short tons/year) (Mg) (short tons) 1980 268,155 294,970 0 0 1981 268,155 294,970 268,155 294,970 1982 268,155 294,970 536,309 589,940 1983 268,155 294,970 804,464 884,910 1984 268,155 294,970 1,072,618 1,179,880 1985 268,155 294,970 1,340,773 1,474,850 1986 268,155 294,970 1,608,927 1,769,820 1987 268,155 294,970 1,877,082 2,064,790 1988 268,155 294,970 2,145,236 2,359,760 1989 268,155 294,970 2,413,391 2,654,730 1990 268,155 294,970 2,681,546 2,949,700 1991 268,155 294,970 2,949,700 3,244,670 1992 268,155 294,970 3,217,855 3,539,640 1993 268,155 294,970 3,486,009 3,834,610 1994 268,155 294,970 3,754,164 4,129,580 1995 268,155 294,970 4,022,318 4,424,550 1996 268,155 294,970 4,290,473 4,719,520 1997 268,155 294,970 4,558,628 5,014,490 1998 268,155 294,970 4,826,782 5,309,460 1999 268,155 294,970 5,094,937 5,604,430 2000 268,155 294,970 5,363,091 5,899,400 2001 720,893 792,982 5,631,246 6,194,370 2002 876,091 963,700 6,352,138 6,987,352 2003 672,597 739,857 7,228,229 7,951,052 2004 684,458 752,904 7,900,826 8,690,909 2005 586,671 645,338 8,585,284 9,443,813 2006 516,584 568,243 9,171,955 10,089,151 2007 547,889 602,678 9,688,539 10,657,393 2008 493,997 543,397 10,236,428 11,260,071 2009 496,385 546,024 10,730,425 11,803,468 2010 570,797 627,877 11,226,811 12,349,492 2011 270,651 297,716 11,797,608 12, 977, 369 2012 0 0 12,068,259 13,275,085 REPORT -2 Landgem- DRLS-Jan.2010 2/15/2010 Results Year Total landfill gas Methane (Mg/year) (m'/year) (av ft^3/min) (Mg/year) (m3 (av ftA3/min) 1980 0 0 0 0 0 0 1981 1.328E+03 1.063E+06 7.142E+01 3.546E+02 5.315E+05 3.571E+01 1982 2.629E+03 2.105E+06 1.414E+02 7.022E+02 1.053E+06 7.072E+01 1983 3.904E+03 3.126E+06 2.101E+02 1.043E+03 1.563E+06 1.050E+02 1984 5.154E+03 4.127E+06 2.773E+02 1.377E+03 2.064E+06 1.387E+02 1985 6.380E+03 5.109E+06 3.433E+02 1.704E+03 2.554E+06 1.716E+02 1986 7.581E+03 6.071E+06 4.079E+02 2.025E+03 3.035E+06 2.039E+02 1987 8.759E+03 7.013E+06 4.712E+02 2.340E+03 3.507E+06 2.356E+02 1988 9.913E+03 7.938E+06 5.333E+02 2.648E+03 3.969E+06 2.667E+02 1989 1.104E+04 8.843E+06 5.942E+02 2.950E+03 4.422E+06 2.971E+02 1990 1.215E+04 9.731E+06 6.538E+02 3.246E+03 4.866E+06 3.269E+02 1991 1.324E+04 1.060E+07 7.123E+02 3.536E+03 5.301E+06 3.562E+02 1992 1.431E+04 1.145E+07 7.696E+02 3.821E+03 5.727E+06 3.848E+02 1993 1.535E+04 1.229E+07 8.258E+02 4.100E+03 6.145E+06 4.129E+02 1994 1.637E+04 1.311E+07 8.809E+02 4.373E+03 6.555E+06 4.405E+02 1995 1.738E+04 1.391E+07 9.349E+02 4.641E+03 6.957E+06 4.674E+02 1996 1.836E+04 1.470E+07 9.878E+02 4.904E+03 7.351E+06 4.939E+02 1997 1.932E+04 1.547E+07 ,1.040E+03 5.162E+03 7.737E+06 5.198E+02 1998 2.027E+04 1.623E+07 1.090E+03 5.414E+03 8.115E+06 5.452E+02 1999 2.119E+04 1.697E+07 1.140E+03 5.661E+03 8.486E+06 5.702E+02 2000 2.210E+04 1.770E+07 1.189E+03 5.904E+03 8.849E+06 5.946E+02 2001 2.299E+04 1.841E+07 1.237E+03 6.142E+03 9.206E+06 6.185E+02 2002 2.611E+04 2.090E+07 1.405E+03 6.973E+03 1.045E+07 7.023E+02 2003 2.993E+04 2.396E+07 1.610E+03 7.994E+03 1.198E+07 8.051E+02 2004 3.266E+04 2.616E+07 1.757E+03 8.725E+03 1.308E+07 8.787E+02 2005 3.541E+04 2.835E+07 1.905E+03 9.457E+03 1.418E+07 9.524E+02 2006 3.761E+04 3.012E+07 2.023E+03 1.005E+04 1.506E+07 1.012E+03 2007 3.942E+04 3.157E+07 2.121E+03 1.053E+04 1.578E+07 1.060E+03 2008 4.135E+04 3.311E+07 2.225E+03 1.105E+04 1.656E+07 1.112E+03 2009 4.298E+04 3.442E+07 2.312E+03 1.148E+04 1.721E+07 1.156E+03 2010 4.459E+04 3.570E+07 2.399E+03 1.191E+04 1.785E+07 1.199E+03 2011 4.653E+04 3.726E+07 2.503E+03 1.243E+04 1.863E+07 1.252E+03 2012 4.695E+04 3.759E+07 2.526E+03 1.254E+04 1.880E+07 1.263E+03 2013 4.602E+04 3.685E+07 2.476E+03 1.229E+04 1.842E+07 1.238E+03 2014 4.511E+04 3.612E+07 2.427E+03 1.205E+04 1.806E+07 1.213E+03 2015 4.421E+04 3.540E+07 2.379E+03 1.181E+04 1.770E+07 1.189E+03 REPORT -3 ATTACHMENT 5 EMISSION CALCULATIONS EMISSION CALCULATIONS SUMMARY DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO POTENTIAL EMISSIONS: F001 & C001 - Landfill Gas Emissions & Flare c'l This represents the total landfill emissions without operation of the GCCS. (b) This represents the maximum emissions from the flare, D:IWas,e Connecrion.rlDenver Regiorral Sou hlr,le ['Minor Mod 2010IEmission Calm -Potential summary Page 1 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO Required: Determine the potential annual emissions from the landfill and flare using the maximum landfill gas (LFG) generation predicted by the EPA LFG generation model. Estimates for VOCs, SO2, HCI and PM10 will be calculated utilizing the U.S. EPA's Compilation of Air Pollutant Emission Factors (AP -42), Section 2.4 for Municipal Solid Waste (MSW) Landfills. NO„ and CO emissions based on manufacturer provided emission factors. The emission factors are converted from lb/MMBtu to lb/MMscf of methane based on the heating value of methane (1,000 Btu/scf). Site Specific Data: 1. Maximum Flare Control Capcity = QF = 3,000 scfm 2. Flare Destruction Efficiency = rletd = 98% References: 1 AP -42 equations used to calculate emissions of VOCs, HCI, and SO,: A. Section 2.4.4.1, Equation 3 is used to calculate the total uncontrolled emission rate of LFG pollutants in m3/yr using the following equation: Qp = 2 QCH4 Cp / 1,000,000 Where: Qp = emission rate of pollutant p, m3/yr QCH4 CH4 generation rate (to flare or as fugitive emissions), m3/yr Cp = concentration of pollutant p in LFG, ppm„ 2 = multiplication factor (assumes 50% CH4 in LFG) B. Section 2.4.4.1, Equation 4 is used to calculate the total uncontrolled mass emissions per year of LFG pollutants in kg/yr using the following equation: UMp = (Q MWp P) / (1,000 R T) Where: UMp = uncontrolled or collected and not combusted mass emission rate of pollutant p, kg/yr Qp = emission rate of pollutant p, m3/yr MWp = molecular weight of pollutant p, g/g-mol P = atmospheric pressure, atm R = universal gas constant, m3-atm/gmol-K T = standard temperature (77 degrees Fahrenheit), Kelvin 2. Equation utilized to account for the destruction efficiency of the flare: CMp F = UMP,F (1 - r1ctrl) Where: CMp,F = UMp,F = rlctrl = controlled emission rate of pollutant p from flare, kg/yr uncontrolled emission rate of pollutant p (influent to flare), kg/yr flare destruction efficiency, % O:Waste ConnectionsDenver Region/-South;Title VMinor Mod 20/0.Enission Calcs-Potential landfill and flare Page 2 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO 3. Based on the maximum control capacity of the flare, as indicated in the Site Specific Data section, the average methane flow rate to the flare will be: QCH4,F = 1,500 22,325,002 scfm of CH4 m3/yr of CH4 (Assumes 50% methane in LFG) 4. Molecular weight and concentration of NMOCs (as hexane) and VOCs in LFG are: MWNMOC = CNMOC = MWvoc = Cvoc = 86.18 595 86.18 232.05 g/g-mol (hexane) ppmv (as hexane) g/g-mol (hexane) ppmv 5. Average molecular weight and concentration of CI is: MWc1 Cc! = 35A5 g/g-mol 42 ppmv 6. Average molecular weight of HCl is: MWHCI = 36A6, g/g-mol 7. Average molecular weight and concentration of sulfur is: MWs = 32.07 g/g-mol Cs = 46.9 ppmv 8. Molecular weight of sulfur dioxide is: 9. MWsO2 = 64.07 g/g-mol (Default from EPA AP -42) (Assumed as equal to NMOC) (39% of NMOC conc. per Operating Permit) (Default from EPA AP -42) (Default from EPA AP -42) Emission factors for CO and NO„ are obtained from the flare manufacturer and converted to the current units assuming 1,000 Btu/scf methane. The particulate matter emission factor is a default factor from EPA's AP -42, Table 2.4-5 (11/98) . EFNoX = EFco EFPM10 = 10. Conversion Factors: 100 lb/MMscf of methane (Flare Manufacturer) 500 lb/MMscf of methane (Flare Manufacturer) 17 lb/MMscf of methane (Default from EPA AP -42) 35.315 ft3 = 1 m3 525,600 min = 1 yr 6.719E-05 scfm CH4 = 1 m3/yr 2,000 lbs = 1 ton 8,760 hr = 1 yr 1.10E-03 tons = 1 kg 77 °F = 298 K O:IWaste Connections' Denver Regional-SouthV7t/e VMinor Mod 20/0iEmission Coles -Potential landfill and pare Page 3 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO Assumptions: 1. Estimated maximum CH4 generation rate predicted by the EPA's LandGEM v3.02 model is: QCH4,G = 18,796,739 m3/yr 1,263 scfm CH4 2,526 scfm LFG 2. The following conditions are assumed in calculating the emissions of VOCs, HCI, and SO2 using Equation 4 provided in Reference 1. P = 1 atm R = 8,205E-05 m3-atm/gmol-K T = 298 K 3. As indicated in AP -42, Section 2.4, in estimating HCI emissions generated by the flare, it is assumed that all of the chloride ions from the combustion of chlorinated LFG constituents is converted to HCI. Calculations: 1. VOC Emissions: A. Landfill Fugitive Emissions 1) Based on the maximum annual methane generation (Assumption 1), calculate the VOC emission rate in m3/yr generated by the landfill using Equation 3 (Reference 1): QVOC, T = 2 QCH4, G CVOs / 1,000,000 QCH4,G = 18,796,739 m3/yr Cvoc = 232.05 ppmv Qvoc,T = 8,724 m3/yr 2) Calculate the mass emission rate of total VOC in kg/yr generated by the landfill using Equation 4 (Reference 1) and Assumption 2: UMvoc, T = (QVOC, T MWvoc P) / (1,000 R T) Qvoc,T = 8,724 m3/yr MWvoc = 86.18 g/g-mol P = 1 atm R = 8.205E-05 m3-atm/gmol-K T = 298 K UMVOC,T = 30,747 kg/yr 3) Convert emissions to tons/yr using conversion factor (Reference 10): UMVOC,T = 33.88 tons/yr 7.74 lbs/hr Waste Connections Denver Regional -South' --Tide VMinor Mod 20/01Emission Calcs-Potential landfill and flare Page 4 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO B. Flare Emissions: 1) Using the maximum methane flare flow rate (Reference 3), calculate the annual VOC emission rate in m3/yr directed to the flare using Equation 3 (Reference 1): QVOC,F = 2 QCH4,F CVOC / 1,000,000 QCH4,F = 22,325,002 m3/yr Cvoc = 232.05 ppmv QVOC,F = 10,361 m3/yr 2) Calculate the mass emission rate of total VOC in kg/yr directed to the flare using Equation 4 (Reference 1) and Assumption 2: UMvoc,F = (Qvoc,F MWvoc P) / (1,000 R T) QVOC,F = 10,361 m3/yr MWvoc = 86.18 g/g-mol P = 1 atm R = 8.205E-05 m3-atm/gmol-K T = 298 K UMvoc,F = 36,519 kg/yr 3) Calculate the controlled VOC emission rate using the flare's destruction efficiency and the equation indicated in Reference 2: CMvoc, F = UMvoc, F (1 - 31ctrl) UMVOC, F rlctrl = 36,519 kg/yr 98% CMvoc, F = 730 kg/yr 3) Convert emissions to tons/yr using conversion factors (Reference 10): CMvoc, F = 0.80 tons/yr 0.18 lbs/hr 2. HCI Emissions from Flare: 1) Using the maximum methane flare flow rate (Reference 3), calculate the emission rate of chlorinated compounds as chloride ions in m3/yr directed to the flare using Equation 3 (Reference 1): QCI, F = 2 QCH4, F Ca / 1,000,000 QCH4, F = 22,325,002 m3/yr Ca = 42 ppmv QCI, F = 1,875 m3/yr O: IWaste ConnecrionsDenver Regiona(South Tide VMinor Mod 20i0!Emission Coles -Potential landfill and flare Page 5 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO 2) Calculate the mass emission rate of chlorinated compounds as chloride ions in kg/yr directed to the flare using Equation 4 (Reference 1) and Assumption 2: UMc1, F = (Qci, F MWci P) / (1,000 R T) Qa,F = 1,875 m3/yr MWci = 35.47 g/g-mol P = 1 atm R = 8.21E-05 m3-atm/gmol-K T = 298 K UMc, F = 2,720 kg/yr 3) Utilizing Equation 10 from AP -42, Section 2.4, calculate the controlled HCl emission rate in m3/yr using the ratio of the molecular weight of HCl to Cl: CMHCI, F = UMci, F = T1atrl = MWHC1 = MWc1 = UMC1, F (r1ctri / 100) (MWHC / MWc1) 2,720 kg/yr 100% 36.46 g/g-mol 35.45 g/g-mol CMHcl, F = 2,797.93 kg/yr 4) Convert emissions to tons/yr using conversion factors (Reference 10): CMHCI, F = 3.08 tons/yr 0.70 lbs/hr 3. SO, Emissions from Flare: (See Assumption 3) 1) Using the maximum methane flare flow rate (Reference 3), calculate the mass emission rate of reduced sulfur compounds as sulfur (S) in m3/yr directed to the flare using Equation 3 (Reference 1): QS,F = 2 QCH4,F Cs / 1,000,000 QCH4,F = 22,325,002 m3/yr Cs = 46.9 ppmv Qs, F 2,094 m3/yr 0.. Waste ConnectionsDenver Regional-SoutMTitle VMinor Mod 20101Emission C:alcs-Potential landfill and flare Page 6 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO 2) Calculate the mass emission rate of reduced sulfur compounds as sulfur in kg/yr directed to the flare using Equation 4 (Reference 1) and Assumption 2: UMs,F = (Qs,F MWs P) / (1,000 R T) Qs, F = 2,094 m'/yr MWs = 32.07 g/g-mol P = l atm R = 8.21E-05 m3-atm/gmol-K T = 298 K UMs, F = 2,747 kg/yr 3) Utilizing Equation 7 from AP -42, Section 2.4, calculate the controlled SO, emissions in kg/yr using a ratio of the molecular weight of SO, to S: CMso2, F = UMs, F (MWso2 / MWs) UMs, F = MWso2 = MWs = 2,747 kg/yr 64.07 g/g-mol 32.07 g/g-mol CMso2, F = 5,487 kg/yr 4) Convert emissions to tons/yr using conversion factors (Reference 10): CMso2, F = 6.05 tons/yr 1.38 lbs/hr 4. NO,, Emissions from Flare: Using the NOx emission factor (Reference 9) and the maximum methane flare flow rate (Reference 3), calculate NOx emissions: NOx = EFNox QCH4,F * 35.315 / (2,000 * 1,000,000) Where: NOx = emission rate of NOx from flare, tons/yr EFNox = emission factor for NON, lb/MMscf methane QCH4,F methane flow to flare, m3/yr methane 35.315 = conversion from m3 to scf 1,000,000 = conversion from MMscf to scf 2,000 = conversion from tons to lb EFNox = 100 lb/MMscf methane QCH4,F = 22,325,002 m3/yr methane NOx = 39.42 tons/yr 9.00 lbs/hr O:'Wasle Connections:DenverRegional-SouthiTttle NMinor Mod 2010'Emission Calcs-Potential landfill and,flare Page 7 of 9 Weaver Boos Consultants, LLC 2/26/2010 LANDFILL AND FLARE POTENTIAL EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO 5. CO Emissions from Flare: Using the CO emission factor (Reference 9) and the maximum methane flare flow rate (Reference 3), calculate CO emissions: CO = EFco QCH4,F * 35.315 / (2,000 * 1,000,000) Where: CO = emission rate of CO from flare, tons/yr EFco emission factor for CO, lb/MMscf methane QCH4,F methane flow to flare, m3/yr methane 35.315 = conversion from m3 to scf 1,000,000 = conversion from MMscf to scf 2,000 = conversion from tons to lb EFco = 500 lb/MMscf methane Qcx4,F = 22,325,002 m3/yr methane CO = 197.10 tons/yr 45.00 lbs/hr 6. PM10 Emissions from Flare: Using the PMIo emission factor (Reference 9) and the maximum methane flare flow rate (Reference 3) calculate PMIo emissions: Where: PMIo = EFPMIo Qcx4,F * 35.315 / (2,000 * 1,000,000) PM10 = EFPMIo = QCH4,F emission rate of PMIo from flare, tons/yr emission factor for PMIo, lb/MMscf methane methane flow to flare, m3/yr methane 35.315 = conversion from m3 to scf 1,000,000 = conversion from MMscf to scf 2,000 = conversion from tons to lb EFPMIo = 17 lb/MMscf methane QCH4,F = 22,325,002 m3/yr methane PM1. = 6.70 tons/yr 1.53 lbs/hr O: (Waste Conneclions,Denver RegionlSouth (Tide NMinor Mod 2010!Emission C alcs-Potential landfill and flare Page 8 of 9 Weaver Boos Consultants, LLC 2/26/2010 ADDITIONAL NON CRITERIA REPORTABLE AIR POLLUTANTS POTENTIAL LANDFILL FUGITIVE EMISSION CALCULATIONS DENVER REGIONAL LANDFILL SOUTH - WELD COUNTY, COLORADO Estimated maximum fugitive landfill CH4 generation rate: 1,1,2,2 - Tetrachloroethane 1,1 - Dichloroethane (ethylidene dichloride) 1,1 - Dichloroethene (vinylidene chloride) 1,2 - Dichloroethane (ethylene dichloride) 1,2 - Dichloropropane (propylene dichloride) Acryl onitri le Benzene Cttrbott Disulfide Chlorobenzene Chloromethane (methyl chloride) Dichlorobenzene° Dichloromethane (methylene chloride) Dimethyl Sulfide (methyl sulfide) Ethylbenzene Hexane Hydrogen Sulfide Methyl Isobutyl Ketone Methyl Mercaptan Perchloroethylene (tetrachloroethylene) Toluene Trichloroethylene (trichloroethene) Vinyl Chloride Xylenes Dichlorodifluoromethane 79-34-5 75-34-3 75-35-4 107-06-2 78-87-5 107-13-1 71-43-2 75-15-0 108-90-7 74-87-3 106-46-7 75-09-2 75-18-3 100-41-4 110-54-3 7783-06-4 108-10-1 74-93-1 127-18-4 108-88-3 79-01-6 75-01-4 1330-20-7 75-71-8 A B A A A A A A A A A A C C C A B A A C C A C C 18,796,739 167.85 98.97 96.94 98.96 112.99 53.06 78.11 76.13 11-2.56 50.49 147.0 84.94 62.13 106.16 86.18 34.08 100.16 48.11 165.83 92.13 131.4 62.5 106.16 120.91 Default concentrations for LFG compounds were obtained from the U.S. EPA's LandGEM version 3.02. These fugitive emissions were calculated by using the equations # 3 and # 4 from AP -42, Section 2.4 (11/98) and by using the site specific concentration for each compound. This represents reportable level of non criteria pollutants. d All orientations of dichlorobenzene are considered the 1,4 orientation. Dichlorodifluoromethane is a potential ozone depleting pollutant, and ozone depleting compounds are listed under BIN C. m3/yr 1.10 2.40 0.20 0.41 0.18 6.33 1.9Q 0.58 0.25 1.20 0.21 14.30 7.80 4.60 6.60 35.50 1.90 2.50 3.73 39.00 2.80 7.34 12.00 15.70 0.071 0.092 0.007 0.016 0.008 0.130 0.057 0.017 0.011 0.023 0.012 0.469 0.187 0.189 0.220 0.468 0.074 0.046 0.239 1.389 0.142 0.177 0.492 0.734 0.313 0.402 0.033 0.069 0,034 0.569 0.251 0.075 0.048 0.103 0.052 2.056 0.820 0.827 0.963 2.048 0.322 0.204 1.047 6.083 0.623 0.777 2.157 3.214 625.1 804.2 65.6 137.4 68.9 1,137.2 502.5 149.5 95.3 205.1 104.5 4,112.4 1,640.8 1,653.4 1,925.8 4,096.2 644.3 407.2 2,094.2 12,165.1 1,245.7 1,553.2 4,313.1 6,427.1 0.025 0.250 0.025 0,025 0.025 0.025 0,025 0.025 0.025 0.025 0.025 0.025 0.500 0.500 0.500 0.025 0.250 0.025 0.025 0.500 0.500 0.025 0.500 0.500 Q:I Wave Connectinn.vIDenver Regional-Souih17i11e VW/lnor Mod 20101Emission Cnlcs-Potential .Sp:Tinted-Gag Page 9 of 9 Weaver Boos Consultants, LLC-Southwest 2/26/2010 ATTACHMENT 6 SUGGESTED DRAFT PERMIT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: FACILITY ID: ISSUE DAlL: EXPIRATION DA'L'E: MODIFICATIONS: Denver Regional Landfill (South) Inc. 1230079 March 1, 2006 March 1, 2011 See Appendix F of Peiuiit OPERATING PERMIT NUMBER 03OPWE254 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-10 1 et seq. and applicable rules and regulations. ISSUED TO: Denver Regional Landfill (South) Inc. 1441 Weld County Road Six, P.O. Box 320 Erie, CO 80516 PLANT SITE LOCATION: 1441 Weld County Road Six Erie, CO Weld County INFORMATION RELIED UPON Operating Permit Application Received: And Additional Infoiniation Received: January 31, 2003 June 10, 2005; July 25, 2007; September 6, 2007 Nature ofBusiness: Municipal solid waste disposal Primary SIC: 4953 RESPONSIBLE OFFICIAL Name: Mark Adams Jeff Burrier Title: Regional Engineering Manager District Manager' 303 708 8359 303; 968-9508 Phone: FACILITY CONTACT PERSON Name: Kevin Horst Jeff Burner" Title: Site Manager District Manager Phone: 303 673 9431303-968-9508 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: January 1 — June 30, July 1 — December 31 Semi -Annual Monitoring Report: Due on August 1, 2006 & February 1, 2007 and subsequent years Annual Compliance Period: January 1 to December 31 Annual Compliance Certification: Due on February 1, 2007 and subsequent years Note that the Semi -Annual Monitoring Reports and Annual Compliance Certifications must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports/certifications. Air Pollution Control Division 'Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 1 1. Permitted Activities 1.1 SECTION I - General Activities and Summary Denver Regional Landfill South (DRLS) is a municipal solid waste landfill and falls under the Standard Industrial Classification 4953. Landfill gas is generated from the decomposition of organic materials found in landfills. Landfill gas is primarily composed of methane and carbon dioxide. Volatile organic compounds (VOC) and hazardous air pollutants (HAP) are present in landfill gas in trace amounts. Landfill gas (LFG) is emitted primarily through two sources. LFG can be emitted as fugitive gas through cover soils or through a LFG migration control system (GMCS). The GMCS is installed to control LFG migration. Collected LFG is sent to a flare for destruction _ Y . or to a dewatering treatment system, which will then route the LFG to a pipeline to be used for sale. During its operation, the flare generates various combustion by-products that are emitted into the atmosphere. Particulate emissions are generated from construction and operation of the landfill, which includes vehicle traffic on paved or unpaved roads, excavation, and the handling of soil cover material. This facility is located at 1441 Weld County Road Six, Erie, Weld County. The area in which the plant operates is designated as attainment for all criteria pollutants ' . This facility is located in the 8 -hr Ozone Control Area as defined in Regulation No.7, II.A.16 There are no affected states within 50 miles of this facility. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park, and Rawah Wilderness Area. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 The Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permit: 12WE652. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV — Conditions 3.d, 3.g (last paragraph), 14 and 18 (as noted). Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 2 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios 2.1 The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 2.1.1 No separate operating scenarios have been specified. 3. Prevention Of Significant Deterioration (PSD) 3.1 This facility is located in an area designated attainment for all ollutantsgex � g P � Based on the information provided by the applicant, it is not categorized as a major stationary source (no single criteria pollutant emissions with a Potential to Emit of greater than 250 TPY as of the issue date of this permit. The source therefore is not subject to the PSD review requirements of 40 CFR 52.21 (Colorado Regulation No. 3, Part D, Section VI). This facility is located in the 8- hr Ozone Control Area as defined in Regulation No.7, II.A.-6 8 -hr Ozone Control been desi natedas anbnat(airi ent�,are p,wr• ,,ai' v� M ozone standard. Future modifications to this facility which are major by itself will result in the application of the PSD review requirements. In addition, future modifications at this facility may result in the facility being classified as a major stationary source. Once that threshold is exceeded, future modifications at this facility resulting in a significant net emissions increase (see Reg. 3, Part D, Sections II.A.27 and 44) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.44 or a modification which is major by itself may result in the application of the PSD review requirements. Operating Permit 99OPWE215 is to be considered in conjunction with this operating permit for purposes of determining the applicability or non -applicability of Prevention of Significant Deterioration (P SD) regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based upon the information provided by the applicant, the sources addressed in this permit are not subject to the provisions of the Accidental Release Prevention Program (section 112(r) of the Federal Clean Air Act). 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: None. Operating Peiiuit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 3 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission Unit Number AIRS Stack Number Unit ID Description Pollution Control Device F001 C001 007 LF-1 GF-1 Landfill gas emissions Custom built Power Strategy Cleanair Flare, EF-90 Air -Assisted Enclosed Flare Treatment and System F003 001 CV -1, PR -1, UPR 1, SP -1 Fugitive particulate emissions Watering Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Air`?ollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 4 SECTION II - Specific Permit Terms 1 F001 & C001 — Landfill Gas Emissions & Flare Parameter Peuiut Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval VOC Emissions 1.1 3Y4 7 21.2 tons/yr EPA's Landfill Gas Emissions Model (Version 2.01 or most current version), or AP -42 2.4 Calculation Annually TSP 1.2 `61 6:4 tons/yr 17 lb/mmdscf methane Recordkeeping & Calculation Monthly PM10 6.7 64 tons/yr 17 lb/mmdscf methane SO2 6 0 5,0 tons/yr AP -42 2.4 CO 197.1 tons/yr 0.5 lb/mmbtu 500 lb/mmdscf methane NOx 39.4 tons/yr 0.1 lb/mmbtu 100 lb /mmdscf methane Landfill gas combustion 1.3 1576.8 million cubic feet/yr Recordkeeping Monthly Flare destruction efficiency 1.4 Reduce VOC least 98%. temperature 1,065.6°F and HAPs by at Maintain flare 1116°F Measurement & Recordkeeping Daily above Standards of Performance for Municipal Solid Waste Landfills 1.5 NSPS Subpart WWW As Defined Treatment 1.6 See Condition 1.6 System Periodic Monitoring NSPS General Provisions 1.7 Subject b NSPS General Provisions Opacity 1.8 Not to exceed 30%. Observation Weekly Method 9 As required National Emission Standards for Hazardous Air Pollutants: MSW Landfills 1.9 . r MACT Subpart AAAA As Defined Odor 1.10 Heat & 1.11 ASTM or alternative (BTU) methane content of landfill gas Monthly Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 5 1.1 Emissions of Volatile Organic Compounds (VOC) from the landfill shall not exceed the limits outlined in Summary Table 1 above. The VOC landfill gas emissions shall be calculated annually using EPA's Landfill Gas Emissions Model (Version 2.01 or the most current version of the model), or the calculation methods outlined in AP -42 2.4. The VOC co centration omissions shall be 39% of the total non -methane organic compound (NMOC) q ;centration emission that is estimated by the model. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3.) 1.2 Pollutant emissions shall not exceed the limits listed in Summary Table 1 above. Compliance with the annual limits shall be determined on a rolling (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site for Division review. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3.). 1.3 Combustion of landfill gas shall not exceed 1576.8 million cubic feet per year. Monthly records of the actual combustion rate shall be maintained by the applicant and made available to the Division for inspection upon request. Compliance with the yearly limit shall be determined on a rolling twelve (12) month total. (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3.). 1.4 This source shall be equipped with an enclosed flare capable of reducing uncontrolled emissions of VOC and HAPs by at least 98%. The temperature of the flare shall be at least 1116°F to achieve this level of control. The flare temperature shall be measured and continuously recorded as described in condition 1.5.5.1 (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3.). 1.5 This facility is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart WWW, Standards of Performance for Municipal Solid Waste Landfills, including, but not limited to, the following: 1.5.1 This facility has submitted to the Division an initial design capacity report and an initial emission rate report in accordance with §60.757 (within ninety (90) days of the effective date of this regulation as required). 1.5.2 Control of MSW landfill emissions in compliance with §60.752 (b). 1.5.3 This facility shall comply with § 60.752 (b)(2)(ii), which requires the installation of a collection and control system that effectively captures the gas generated within the landfill. The system design, approved by the Division, meets the following requirements: 1.5.3.1 An open flare designed and operated in accordance with the parameters established in §60.18 (General Provision); or 1.5.3.2 A control system designed and operated to reduce NMOC by 98 weight percent; or Operating Peiiiiit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 AirPollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 6 `l5 1.5.3.1 An enclosed combustion device designed and operated to reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen. 1.5.4 This landfill has a design capacity equal to or greater than 2.5 million megagrams or 2.5 million cubic meters, and is therefore subject to part 70 permit requirements. 1.5.5 The owner or operator shall calibrate, maintain, and operate the following equipment associated with the enclosed flare according to the manufacturer's specifications: 1.5.5.1 A temperature monitoring device equipped with a continuous recorder and having an accuracy of +/- 1 percent of the temperature being measured expressed in degrees Celsius or +/- 0.5 °C whichever is greater. 1.5.52A gas flow rate measuring device that provides a measurement of gas flow to or bypass of the control device. The owner or operator shall either: a. Install, calibrate, and maintain a gas flow rate measuring device that shall record the flow to the control device at least every 15 minutes; or b. Secure the bypass line valve in the closed position with a car -seal or a lock -and -key type configuration. A visual inspection of the seal or closure mechanism shall be performed at least once every month to ensure that the valve is maintained in the closed position and that the gas flow is not diverted through the bypass line. 1.5.6 This facility must comply with §70.6(a)(3)(ii) for all applicable collection and control system scenarios. 1.5.6.1 The facility must maintain a log of all calibration, maintenance, and significant operational activities associated with this device. This log must kept on site at all times and made available to the Division upon request. 1.5.62 Manufacturer specifications, which must include proper calibration, maintenance, and operation guidelines, must be kept on site at all times for this device and made available to the Division upon request. 1.5.7 The facility shall comply with the following requirements: 1.5.7.1 §60.753 Operational standards for collection and control systems 1.5.7.2 §60.754 Test methods and procedures 1.5.7.3 §60.755 Compliance provisions 1.5.7.4 §60.756 Monitoring of operations 1.5.7.5 §60.757 Reporting requirements 1.5.7.6 §60.758 Recordkeeping requirements 1.5.7.7 §60.759 Specifications for active collection systems Operating Peuiiit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Air t'ollution Control Division Colorado Operating Peuuuit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 7 1.5.8 This facility shall comply with the most recently approved Gas Collection and Control System plan dated September 6, 2007, which Colorado approved by letter dated (to be determined), except that, if there are later revisions to the plan, this facility shall comply with the most recent plan Colorado has approved in writing in accordance with §60.752(b)(2)(iv) and §60.759. 1.6 [REMOVED] , approval of the GCCS Plan dated September 6, 2007. This treatment system consists of a compressor, filters, and dewatering equipment. 1.6.1 A gas flow rate measuring device that provides a measurement of gas flow to or bypass of the control device. The owner or operator shall either: a. Install, calibrate, and maintain a gas flow rate measuring device that shall record the flow to the control device at least every 15 minutes; or b. Secure the bypass line valve in the closed position with a car seal or a lock and key type configuration. A visual inspection of the seal or closure mechanism shall be performed at least once every month to ensure that the valve is maintained in the closed position and that the gas flow is not diverted through the bypass line. 1.6.3 The pressure drop operating range across the filtration system shall be within 60 to 100 psi and recorded continuously in a log. This log shall be kept on site at all times and made available to the Division upon request. 1.6.2 The temperature of the exit gas shall be below 50°F and continuously monitored in a log. The temperature shall be reported using a 24 hour average. This log shall be kept on site at all times and made available to the Division upon request. 1.7 In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. 1.7.1 At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Detetiiiination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11) 1.7.2 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 f Air'ollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 8 1.7.3 Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. 1.7.4 Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. 1.7.5 Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under § 60.7. 1.7.6 Performance tests shall be conducted as required under § 60.8. 1.7.7 Compliance with opacity standards shall be demonstrated according to § 60.11. 1.8 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes (Colorado Regulation No.1, II.A.5). The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992) (Colorado Regulation No. 1, ILA. 1). A visible observation of the flare must be conducted weekly. If visible emissions are present during the weekly observation, an opacity reading shall be performed in accordance with Method 9, the cause of the visible emissions should be investigated, and corrective action taken. At least one reading shall be performed in accordance with EPA Method 9 annually. Records of the weekly observations and Method 9 observations shall be maintained and made available for Division inspection upon request. 1.9 This source is subject to the National Emissions Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) as follows: 1.9.1 The permittee must develop and implement a written SSM plan according to the provisions in 40 CFR 63.6(e)(3). A copy of the SSM plan must be maintained on site. 1.9.2 The annual reports described in 40 CFR 60.757(f) must be submitted every 6 months. 1.9.3 The permittee must comply with the general provisions of this part specified in table 1 of this subpart. 1.10 This source is subject to the odor requirements of Regulation Number 2 (state only). 1.11 The heat (BTU) content of the landfill gas shall be -determined semi-annually per the appropriate ASTM method, or an alternative method if approved in advance by the Division. At least four months shall separate each determination. The methane content of the landfill gas shall be determined monthly semi annually. At least four months shall separate each determination. All calculations requiring the use of the landfill gas heat content or methane content shall utilize the most recent analytical results monthly data. Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 4 Air pollution Control Division Colorado Operating Pe_uiit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 9 2. F003 — Fugitive Particulate Matter Emissions Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 2.1 q�rttikk 342.5 tons/yr Certification Semi-annually PMio n 4, �#�}� l�� 72.6 tons/yr Waste Acceptance 2.2 1.5 million tons/yr Recordkeeping Monthly Fugitive Particulate Matter Emissions 2.3 Not to exceed 20% opacity Per Division approved control plan Visual observation Weekly No off -property transport No nuisance conditions created Fugitive Emissions Control Plan 2.4 Certification Semi-annually 2.1 Particulate Matter (PM and PM1 0) emissions shall not exceed the limits that are outlined in the table above. The implementation of the Fugitive Emissions Control Plan serves as a demonstration of compliance with this condition. The owner/operator shall certify semi-annually that the Fugitive Emissions Control Plan is being implemented and followed. (Construction Permit 12W652, as modified under the provisions of Section I, Condition 1.3.) 2.2 Waste acceptance shall not exceed 1.5 million tons per year (Construction Permit 12WE652, as modified under the provisions of Section I, Condition 1.3). Actual waste acceptance shall be recorded monthly. A twelve-month rolling total will be maintained to monitor compliance with the annual limitation. 2.3 A weekly check of the facility shall be conducted to determine if the control practices of Condition 2.4 are being implemented and are effective. Records of the observations shall be maintained and made available for Division review upon request. (NOTE: The 20% opacity, no off -property transport, and nuisance emission limitation are guidelines and not enforceable standards and no person shall be cited for violation thereof pursuant to C.R.S. 1973, 25-7-115 as amended.) 2.3.1 20% opacity - During the weekly check, when visible emissions persist for longer than fifteen (15) continuous minutes, the cause shall be determined and corrective actions taken. In addition, a revised Fugitive Emissions Control Plan shall be submitted within 30 days for Division review and approval. A record of the existing condition and the action taken shall be maintained and made available to the Division for review upon request. 2.3.2 Off -Property Transport and Nuisance Provision - During the weekly check, when visible emissions exist within the facility fence line and they persist for longer than fifteen (15) continuous minutes, an inspection shall be made to determine if the visible emissions are being transported off the property on which the source is located. If there is off -property Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1., 2008 AiiPollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 10 transport of the visible emissions, the cause shall be determined and corrective actions taken. In addition, a revised Fugitive Emission Control Plan shall be submitted within thirty (30) calendar days for Division review and approval. A record of the existing condition and the action taken shall be maintained and made available to the Division for review upon request. As used herein, "nuisance" shall mean the emission of fugitive particulate which constitutes a private or public nuisance as defined in common law, the essence of which is that such emissions are unreasonable interfering with another person's use and enjoyment of his property. Such interference must be "substantial" in its nature as measured by a standard that it would be of definite offensiveness, inconvenience, or annoyance to a normal person in the community. 2.4 The owner/operator shall apply such control measures and operating procedures as are necessary to minimize fugitive particulate emissions (Colorado Regulation No. 1, Section IILD. 1 .a). The owner/operator shall certify semi-annually that all appropriate measures have been taken to minimize fugitive emissions. The following fugitive emission control measures shall be used for enforcement purposes on the fugitive emission producing sources, as required by Colorado Regulation No.1 (Construction Permit 12WE652). 2.4.1 Adequate soil moisture must be maintained in topsoil and overburden to control emissions during removal. Watering shall be implemented if necessary. 2.4.2 Topsoil and overburden stockpiles shall be compacted and revegetated within one year. 2.4.3 Emissions from material handling (i.e. removal, loading, and hauling) shall be controlled by watering at all times unless natural moisture is sufficient to control emissions. 2.4.4 Vehicle speed on unpaved roads and disturbed areas shall not exceed a maximum of 5 20 m.p.h. Speed limit signs shall be posted. 2.4.5 Unpaved haul roads shall be watered as often as needed to control fugitive particulate emissions. 2.4.6 All disturbed areas shall be revegetated, as needed. according to the information submitted by the applicant with the permit application. 2.4.7 Reclamation works and sequential extraction of material shall be initiated to keep the total disturbed areas at any one time to a minimum. Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Ait Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 1 APPENDIX A - Inspection Information Directions to Plant: The DRLS is located approximately 1.5 miles southeast of Erie, Colorado, at 1441 Weld County Road 6. Access to the landfill is from Interstate 25, Colorado Highways No. 52 and 7, and Weld County Road 5. Safety Equipment Required: Safety Shoes Hard Hat Facility Plot Plan: Figure 1 (following page) shows the site map as submitted on January 31, 2003 with the source's Title V Operating Permit Application. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list,- activities may have changed since the last filing. Storage tanks with annual throughput less than four hundred thousand gallons of diesel fuel (Reg 3 Part C, ll.E.3 .fff.(ii)(A)) • One 6,000 gallon above ground off -road fuel storage tank • One 0 1,000 gallon above ground on road fuel storage tank twawmilm nd�o� oad e Sa t .MER n„,Ic Fuel storage and dispensing equipment in ozone attainment areas operated solely for company -owned vehicles where the daily fuel throughput is no more than four hundred gallons per day, averaged annually (Reg. 3, Part C, II.E.3.ccc). • tl'TO 500 gallon gasoline UST Landscaping and site housekeeping devices equal to or less than ten horsepower in size (Reg. 3, Part C, II.E.3.bb). Chemical storage tanks or containers that hold less than five hundred gallons, and that have an annual average throughput less than twenty-five gallons per day (Reg. 3, Part C, II.E.3.n). • Miscellaneous routine vehicle and site maintenance materials stored in drums and containers it areas having uncontrolled actual emissions of any criteria pollutant of less .11.1.3.a) [Please update the nonattainrnent designation for the southern portion of Weld County.] .r o -Pk • Leachate and condensate management activities • (1) Air compressor, 12O (1) Power washer, 16111.1''''2 (I) Light plant, 16,7 hp (1) Weed eater, 2,8 cc. (1) Welder, 624 cc Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 September 5, 2017 Mr. Jayson Ellis Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Title V Operating Permit Minor Modification Denver Regional Landfill South Permit Number 03OPWE254 Facility ID: 1230079 Project No. 0601-355-50-64-00 Dear Mr. Ellis: Please find the attached Title V Operating Permit Minor Modification for the Denver Regional Landfill South (DRLS). The facility operates under Title V Operating Permit No. 03OPWE254 issued on March 1, 2006, which was revised on February 1, 2008. An Operating Permit Renewal Application and Minor Modification were submitted to the Colorado Department of Public Health and Environment Air Pollution Control Division (Division) on February 26, 2010. DRLS currently operates under a permit shield as afforded by the last renewal. This modification qualifies as a minor modification under provisions in Regulation 3, Part C, Section X.A, as the requested modification: • Does not violate any applicable requirement and does not involve significant changes to existing, reporting, or recordkeeping requirements; • Does not request or change a case -by -case determination of an emission limitation or other standard; • Does not seek to establish or change a permit condition or condition for which there is no underlying applicable requirement, and for which the source has assumed to avoid an applicable requirement for which the source would otherwise be subject; and • Is not excepted from the definition of permit modification in Regulation 3, Part C, Section I.A.3 and is not otherwise required to be processed as a significant modification. This minor permit modification is being submitted to add language to the opacity observation requirements in the site's Title V Operating Permit. Landfill Energy Services operates a gas -to - energy facility which combusts the landfill gas collected from DRLS. As such, the site's enclosed flare acts as the secondary combustion device. Permit condition 1.8 requires the site to conduct a weekly visible observation of the flare and an annual U.S. Environmental Protection Agency Mr. Jayson Ellis September 5, 2017 Page 2 Method 9 observation. It is requested that the following language be added to the permit condition: "If the flare is not operated during the annual (calendar year) period, then no weekly opacity observations or annual Method 9 observations are required." A copy of this submittal has been placed in the site's operating record for this facility. During the course of your review, if you should have any questions or comments regarding this submittal, please do not hesitate to contact Melissa Green at 720.529.0132 or mgreen@wcgrp.com. We appreciate the Division's assistance with this minor permit modification. Responsible Official Certification SCI I 7 6,0 o 1-/q9 I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate, and complete. Sincerely, Denver Regional Landfill (South) Inc. Mark Adams Engineering Manager Attachments: 1— Operating Permit Modification Forms 2 — Modifications Requested to the Operating Permit cc: Melissa Green, Weaver Consultants Group F: \ADMIN\DRLS\AIR PERMITTING\TITLE V PERMIT MOD12017-08\COVER LTR.DOCX ATTACHMENT 1 OPERATING PERMIT MODIFICATION FORMS FACILITY IDENTIFICATION (FORM 2000-100) Operating Permit Application FACILITY IDENTIFICATION Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and mailing address Name Street or Route City, State, Zip Code Denver Regional Landfill South P.O. Box 320 Erie, Colorado 80516 2. Facility location (No P.O. Box) 3. Parent corporation Street Address 1441 Weld County Road Six City,County, Zip Code Erie, Colorado 80516 Name Street or Route City, State, Zip Code Country (if not U.S.) Denver Regional Landfill (South), Inc. 6855 South Havana, Suite 300 Centennial, Colorado, 80112 4. Responsible official Name Title Telephone Mark Adams Engineering Manager 303-288-2100 5. Permit contact person (If Different than 4) 6. Facility SIC code: 4953 Name Title Telephone Kyle Regan Technical Engineering Supervisor 408-930-2544 7. Facility identification code: CO 1230079 8. Federal Tax I. D. Number: 930923492 9. Primary activity of the operating establishment: Municipal Solid Waste Disposal 10. Type of operating permit ❑ New ❑x Modified ❑ Renewal 11. Is the facility located in a "nonattainment" area: ❑x Yes ❑ No If "Yes", check the designated "non -attainment" pollutant(s): ❑ Carbon Monoxide Ll Ozone ❑ PM10 ❑ Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. 03OPWE254 Renewed February 2010 GCCS Design Plan Approved December 2010 SSM Plan Approved December 2010 Landfill GCCS GCCS 1 FACILITY IDENTIFICATION -- Form 2000-100 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Use "NA" where necessary to identify an information request that does not apply. One form should be included with each application. Item 1 Provide full business name and address of corporation, company, association, society, firm, partnership, individual or political subdivision of the state submitting the application. Item 2 Street address where the air pollution sources are or will be located. For remote locations, land plat descriptions (Township, Range, Section, Subsection location) are acceptable. Item 3 If wholly or partly owned by another entity, identify that entity. Item 4 The responsible official is a person legally responsible for the operation of the permitted air pollution sources. For a corporation, this person must be the president, vice-president, secretary or treasurer, or other person with a similar level of responsibility in the company. Prior to filing the application, if you want the Division to approve your choice of responsible official you may send a letter to the Division describing that person's authority in the company and requesting the Division's approval. Item 5 Individual to contact during the permitting process for additional information concerning the air pollution sources. Item 6 The primary Standard Industrial Classification (SIC) code for the facility where the source(s) are located. Item 7 Provide the facility identification (FED) code. The Division has assigned.a unique code to your facility. The code begins with "CO" (Colorado) and has 7 digits. Item 8 Provide the Facility Federal Tax Number. This is a nine -digit number. Item 9 Provide a short statement about your facility's activities such as "lead -acid battery manufacture" or "sulfite paper mill." Item 10 Indicate the type of permit application being submitted. An applicant may at any time request an operating permit that is otherwise not required. Item 11 Indicate whether the facility is located in a nonattainment areaeven if your facility does not emit the pollutant. Please refer to the instruction booklet and Appendix G of the instruction book. If the area is attainment for all pollutants, enter "Attainment for all Pollutants". Item 12 Identify all facility air pollution permits, plan approvals (fugitive dust), and exemptions issued by U.S. EPA or Colorado APCD that are still in effect. Include grandfathered emission units. Please do not list old permits, exemptions, etc. that have expired or been superseded by more recent approvals. List the permit number, date, and unit or operation covered by the permit. - Example: 88DE189 May 15, 1989 Fugitive Dust Sept 1, 1992 Grandfathered Feb 2, 1972 Incinerator Gravel Pit 2 Smith Boiler RESPONSIBLE OFFICIAL CERTIFICATION (FORM 2000-800) Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Denver Regional Landfill South I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code: CO 1230079 This application contains the following forms: 2 Form 2000-100, Facility Identification ❑ Form 2000-101, Facility Plot Plan ❑ Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing ❑ Form 2000-200, Stack Identification U Form 2000-300, Boiler or Furnace Operation ❑ Form 2000-301, Storage Tanks ❑ Form 2000-302, Internal Combustion Engine U Form 2000-303, Incineration ❑ Form 2000-304, Printing Operations ❑ Form 2000-305, Painting and Coating Operations U Form 2000-306, Miscellaneous Processes U Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: U Form 2000400, Miscellaneous ❑ Form 2000-401, Condensers ❑ Form 2000-402, Adsorbers ❑ Form 2000-403, Catalytic or Thermal Oxidation ❑ Form 2000404, Cyclones/Settling Chambers U Form 2000-405, Electrostatic Precipitators U Form 2000-406, Wet Collection Systems ❑ Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler, printing operation, U Form 2000-500, Compliance Certification - Monitoring and Reporting ❑ Form 2000-501, Continuous Emission Monitoring U Form 2000-502, Periodic Emission Monitoring Using Portable Monitors U Form 2000-503, Control System Parameters or Operation Parameters of a Process ❑ Form 2000-504, Monitoring Maintenance Procedures U Form 2000-505, Stack Testing ❑ Form 2000-506, Fuel Sampling and Analysis ❑ Form 2000-507, Recordkeeping ❑ Form 2000-508, Other Methods 1 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ❑ Form 2000-600, Emission Unit Hazardous Air Pollutants ❑ Form 2000-601, Emission Unit Criteria Air Pollutants ❑ Form 2000-602, Facility Hazardous Air Pollutants ❑ Form 2000-603, Facility Criteria Air Pollutants ❑ Form 2000-604, Applicable Requirements and Status of Emission Unit ❑ Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan — Commitments and Schedule ❑ Form 2000-607, Plant -Wide Applicable Requirements ❑ Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE ❑ I certify that the facility described in this air pollution permit application requirements. formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in © I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): * (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes or certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Mark Adams Title Engineering Manager Signature Date Signed `1Jr) 'q- r.,, ra_'� % * Please note that the site has submitted a permit modification to the APCD to address previously noted non-compliance issues. 2 Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Denver Regional Landfill South Facility Identification Code: CO 1230079 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY ❑ I certify that the facility described in this air pollution permit application requirements. formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable false material statement, representation, misdemeanor and may be punished in © I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): * (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes_any or certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Mark Adams Title Engineering Manager Signature a Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-S S -B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 * Please note that the site has submitted a permit modification to the APCD to address previously noted non-compliance issues. 3 ATTACHMENT 2 MODIFICATIONS REQUESTED TO THE OPERATING PERMIT Modifications Requested to the Operating Permit Section II - Specific Permit Terms Permit Condition 1.8 It is requested that the following language be added to the permit condition: If the flare is not operated during the annual (calendar year) period, then no weekly opacity observations or annual Method 9 observations are required. F:\ADMIN\DRLS\AIR PERMITTING\TITLE V PERMIT MOD\2017-08\COVER LTR.DOCX OPERATING PERMIT REPLACEMENT PAGE Air Pollution Control Division Colorado Operating Permit Permit # 03OPWE254 Denver Regional Landfill (South) Inc. Page 8 1.7.4 Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. 1.7.5 Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under § 60.7. 1.7.6 Performance tests shall be conducted as required under § 60.8. 1.7.7 Compliance with opacity standards shall be demonstrated according to § 60.11. 1.8 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes (Colorado Regulation No.1, II.A.5). The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992) (Colorado Regulation No. 1, II.A.1). A visible observation of the flare must be conducted weekly. If visible emissions are present during the weekly observation, an opacity reading shall be performed in accordance with Method 9, the cause of the visible emissions should be investigated, and corrective action taken. At least one reading shall be performed in accordance with EPA Method 9 annually. Records of the weekly observations and Method 9 observations shall be maintained and made available for Division inspection upon request. If the flare is not operated during the annual (calendar year) period, then no weekly opacity observations or annual EPA Method 9 observations are required. 1.9 This source is subject to the National Emissions Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills (40 CFR Part 63, Subpart AAAA) as follows: 1.9.1 The permittee must develop and implement a written SSM plan according to the provisions in 40 CFR 63.6(e)(3). A copy of the SSM plan must be maintained on site. 1.9.2 The annual reports described in 40 CFR 60.757(f) must be submitted every 6 months. 1.9.3 The permittee must comply with the general provisions of this part specified in table 1 of this subpart. 1.10 This source is subject to the odor requirements of Regulation Number 2 (state only). The heat (BTU) content of the landfill gas shall be determined semi-annually per the appropriate ASTM method, or an alternative method if approved in advance by the Division. At least four months shall separate each determination. The methane content of the landfill gas shall be determined semi-annually. At least four months shall separate each determination. All calculations requiring the use of the landfill gas heat content or methane content shall utilize the most recent analytical results. Operating Permit Number: 03OPWE254 Issued: March 1, 2006 Last Revised: February 1, 2008 Hello