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Home My WebLink About20182444.tiffRECEIVED COLORADO JUL 27 2018 Department of Public Health & Environment ^^WEEL�DCOUNTY ! 3 Dedicated to protecting and improving the health and environment of the people o Coii�a �ON ERS Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 July 25, 2018 Dear Sir or Madam: On July 26, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Front Range Landfill Inc. - Front Range Landfill. 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 a 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 Offi,or public. ReArtoAi O8 -DI -18 ec: PW(ER/ cfi (3wt%C�k)' O7-30-18 2018-2444 Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Front Range Landfill Inc. - Front Range Landfill - Weld County Notice Period Begins: July 26, 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: Front Range Landfill Inc. 1830 Weld County Road 5 Erie, CO 80216 Facility: Front Range Landfill 1830 Weld County Road 5 Erie, CO 80216 Front Range Landfill Inc. has applied to renew the Operating Permit for the Front Range Landfill in Weld County, CO. Front Range Landfill 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. Front Range Landfill is located adjacent to Denver Regional Landfill North, Denver Regional Landfill South, and the Timberline Energy facility and are considered to be a single stationary source. The permit was modified during this renewal to make the permit more consistent with recently issued permits. This includes adding requirements address in PS Memo #12-01 and NSPS WWW. Construction permit 11WE1680 was rolled into the operating permit and the approved minor modification request of 2,230,000 tons per year of waste acceptance as also added. The majority of the emission changes came from the increase in waste acceptance and the change to calculating PCS emissions from the PS Memo. Both changes in emissions were below the significance level for PM and VOC. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 97OPWE188 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 1I COLORADO Wiosie . 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 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. 21 Colorado Department of Public Health and Environment OPERATING PERMIT Front Range Landfill, Inc. First Issued: October 1, 2000 Renewed: X)0( 1, 2018 AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: FACILITY ID: ISSUE DATE: EXPIRATION DATE: MODIFICATIONS: Front Range Landfill OPERATING PERMIT NUMBER 1230079 XXXXX 1, 2018 XXXXX 1, 2023 See Appendix F of Permit 97OPWE188 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seg. and applicable rules and regulations. ISSUED TO: Front Range Landfill, Inc. 1830 Weld County Road 5 Erie, CO 80516 PLANT SITE LOCATION: Front Range Landfill 1830 Weld County Road 5 Erie, CO 80516 INFORMATION RELIED UPON Operating Permit Application Received: And Additional Information Received: July 1, 2010 July 20, 2012, March 31, 2016 Nature of Business: Municipal Solid Waste Disposal Primary SIC: 4953 RESPONSIBLE OFFICIAL Name: Randy Tourville Title: District Manager FACILITY CONTACT PERSON Name: Randy Tourville Title: District Manager Phone: 303-673-9431 Phone: 303-673-9431 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: .1'B) October - March, April - September Semi -Annual Monitoring Report: BI) November I, 2006 & May I. 2007 and subsequent years Annual Compliance Period: ' TBD October 1 to September 30 Annual Compliance Certification: TBD November 1, 2006 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. Non -Attainment New Source Review (NANSR) and 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 3 SECTION II - Specific Permit Terms 4 1. F001 — Fugitive Particulate Matter Emissions 4 2. P001 - Uncollected landfill gas emissions 5 3. P002 - Gas Collection and Control System 7 4. P003 - 550 Gallon Gasoline Tank 16 5. P004 — Degreasing Unit 18 SECTION III - Permit Shield 20 1. Specific Non -Applicable Requirements 20 2. General Conditions 20 3. Stream -lined Conditions 20 SECTION IV - General Permit Conditions ver 5/22/12 21 1. Administrative Changes 21 2. Certification Requirements 21 3. Common Provisions 21 4. Compliance Requirements 25 5. Emergency Provisions 26 6. Emission Controls for Asbestos 26 7. Emissions Trading, Marketable Permits, Economic Incentives 26 8. Fee Payment 26 9. Fugitive Particulate Emissions 27 10. Inspection and Entry 27 11. Minor Permit Modifications 27 12. New Source Review 27 13. No Property Rights Conveyed 27 14. Odor 27 15. Off -Permit Changes to the Source 27 16. Opacity 28 17. Open Burning 28 18. Ozone Depleting Compounds 28 19. Permit Expiration and Renewal 28 20. Portable Sources 28 21. Prompt Deviation Reporting 28 22. Record Keeping and Reporting Requirements 29 23. Reopenings for Cause 30 24. Section 502(b)(10) Changes 30 25. Severability Clause 30 26. Significant Permit Modifications 31 TABLE OF CONTENTS: 27. Special Provisions Concerning the Acid Rain Program 31 28. Transfer or Assignment of Ownership 31 29. Volatile Organic Compounds 31 30. Wood Stoves and Wood burning Appliances 32 APPENDIX A 1 Inspection Information 1 1. Directions to Plant: 1 2. Safety Equipment Required: 1 3. Facility Plot Plan: 1 4. 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 E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 1 1. Permitted Activities 1.1 SECTION I - General Activities and Summary Front Range Landfill 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 facility is located in Erie, Weld County, Colorado. 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 withthe 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 permits: 91 WE766 & 11 WE 1680. 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 97OPWE188 First Issued: October 1, 2000 Renewed: 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 2. Alternative Operating Scenarios Front Range Landfill, Inc. Front Range Landfill Page 2 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. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 Front Range Landfill is located adjacent to Denver Regional Landfill North, Denver Regional Landfill South, 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, 03OPWE254 and 12OPWE376 are to be considered in conjunction with this operating permit for purposes of determining the applicability or non - applicability of Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based upon the information provided by the applicant, this facility is 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 Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Front Range Landfill, Inc. Front Range Landfill Page 3 Emission Unit ID AIRS Stack Number Description Pollution Control Device F001 009 Fugitive particulate emissions Fugitive emissions control plan P001 009 Uncollected landfill gas emissions N/A P002 009 Gas collection and control system Open flare P003 N/A 550 gallon gasoline storage tank N/A P004 N/A Degreasing Unit N/A Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 4 SECTION II - Specific Permit Terms 1. F001 — Fugitive Particulate Matter Emissions Parameter Permit Condition Number Limitations Monitoring Method Interval PM 1.1 269.9 tons/yr Certification Semi-annually PM10 83.7 tons/yr PM2.5 8.7 tons/yr Fugitive Emissions Control Plan 1.2 _ Certification Semi-annual 1.1 Particulate Matter (PM, PM10, and PM2.$) emissions shall not exceed the limits that are outlined in the table above. In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed provided the landfill is operated in accordance the requirements in Conditions 1.2 and 2.4. (91WE766, 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 based on requested emissions identified on the APEN submitted on March 31, 2016) 1.2 The source shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions (Colorado Regulation No. 1, Section III.D.1.a). The source shall certify semi-annually that all appropriate measures have been taken to minimize fugitive emissions. The following particulate emissions control measures shall be used for enforcement purposes on the particulate emission producing sources, as required by Colorado Regulation No. 1 (Construction Permit 91WE766, as modified under the provisions of Section I, Condition 1.3): 1.2.1 Fugitive particulate emissions from land clearing, topsoil, and overburden removal and disturbed areas shall be controlled by watering or use of chemical suppressants as necessary. 1.2.2 Inactive stockpiles and closed landfill areas shall be revegetated and/or watered as necessary to control fugitive particulate emissions. 1.2.3 Fugitive particulate emissions from haul roads shall be controlled by frequent watering. Frequent watering shall be 2 or more times per day when the site is operating and more often if necessary to control visible dust emissions. Watering is not required when natural precipitation and/or chemical stabilizers or wetting agents provide adequate dust emissions control. Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed:''XXX:XX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 2. P001 - Uncollected landfill gas emissions Front Range Landfill, Inc. Front Range Landfill Page 5 Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission Limits 2.1 VOC: 114.5 tons/year CO: 4.9 tons/year EPA Landfill Gas Estimation Model or EPA AP -42 2.4 Recordkeeping & Calculation Annual PCS Acceptance Determinationz 2.2 y "a See PS Memo #12-01 Recordkeeping/ Calculation Monthly/ Annually PCS Exposure Time 2.3 Cover within 24 hours of acceptance ,„ Recordkeeping See Condition 1.3 Waste Acceptance 2.4 2,230,000 tons/year r Recordkeeping Monthly Design Capacity 2.5 35,768,342 Mg See Condition 1.5 2.1 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 2.4 and from previous years. (Construction Permit 91WE766, 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 February 28, 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. Parameter Considerable Quantities of PCS Methane Generation Rate Constant "k" 0.02 or valid Tier 3 test result Methane Generation Potential "Lo" 100 NMOC (as hexane) 2420 ppmv or valid Tier 2 test result Benzene 11.0 or 11.1 ppmv or Division approved LFG sample Toluene 165 or 170 ppmv or Division approved LFG sample Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed:, XX:XX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 6 VOC 85% of NMOC Other HAPs As defined by AP -42 Chapter 2.4 2.2 Acceptance of Petroleum Contaminated Soils (PCS) shall be tracked on a monthly basis and an annual calendar total shall be maintained. 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 February 28, 2018) 2.3 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 February 28, 2018) 2.4 The waste acceptance rate shall not exceed 2,230,000 tons/yr. (Construction Permit 91WE766, 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 February 28, 2018) 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. 2.5 The reported design capacity of the landfill is 35,768,342 Megagrams (Mg). The facility submitted an amended design capacity report to the Division in July 2010 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 97OPWE188 First Issued: October 1, 2000 Renewed. XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE1 88 3. P002 - Gas Collection and Control System Front Range Landfill, Inc. Front Range Landfill Page 7 Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission Limits 3.1 PM:4.5 tons/year PM10: 4.5 tons/year NOx: 17.9 tons/year CO: 97.3 tons/year VOC: 2.5 tons/year SO2: 4.0 tons/year PM: 17 lb/106 dscf methane PM10: 17 lb/106 dscf methane NOx: 68 lb/106 dscf methane CO: 370 lb/106 dscf methane VOC: 98% destruction SO2: AP -42 Ch. 2.4 Recordkeeping & Calculation Monthly & Annual Landfill Gas Combustion 3.2 1,051.2 MMscf/year - Recordkeeping Monthly & Annual Methane Content 3.3 Recordkeeping & Calculation Monthly Standards of Performance for Municipal Solid Waste Landfills 3.4 NSPS Subpart WWW As Defined NSPS General Provisions 3.5 Subject to NSPS General Provisions National Emission Standards for Hazardous Air Pollutants: MSW Landfills 3.6 MACT Subpart AAAA As Defined 3.1 Emissions of air pollutants shall not exceed the limits listed in the table above. The permit holder shall calculate monthly emissions of PM, PM10, 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 monitored from the main header. By the end of each month a new twelve month total for PM, PM10, CO, NON, SO2, and VOC from the control device is calculated based on the previous twelve months' data. (Construction Permit 11 WE1680, 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 February 28, 2018) The VOC emissions from the control device shall be determined based on the actual measured amount of gas sent to the control device. 3.2 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXX.X 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 8 maintained by the applicant and made available to the Division for inspection upon request. (Construction Permit 11WE1680, as modified under the provisions of Section I, Condition 1.3) 3.3 The methane content of the landfill gas (% volume) shall be determined monthly using a Non - Dispersive InfraRed (NDIR) analyzer, GEM -500, or equivalent instrument. The analyzer shall be calibrated using the manufacturer's specifications. If multiple determinations of the methane content monitored from the main header are made in a month, then the monthly value shall be the average of all of the month's determinations. All calculations requiring the use of the landfill gas methane content shall utilize the monthly average results. The permit holder shall maintain a record including the date, calibration results, methane content determinations and the monthly methane content average if applicable. This record shall be made available to the Division upon request. (Construction Permit 11WE1680, as modified under the provisions of Section I, Condition 1.3) 3.4 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.] 3.4.1 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)) 3.4.2 Route all the collected gas to an open 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. (§60.752(b)(2)(iii)) 3.4.3 The collection and control system may be capped or removed provided that all the following conditions are met: (§60.752(b)(2)(v)) 3.4.3.1 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWEl88 Front Range Landfill, Inc. Front Range Landfill Page 9 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)) 3.4.3.2 The collection and control system shall have been in operation a minimum of 15 years; and (§60.752(b)(2)(v)(B)) 3.4.3.3 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)) 3.4.4 The gas collection and control system shall be operated as follows: 3.4.4.1 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)) 3.4.4.2 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)) 3.4.4.3 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)) 3.4.4.4 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 Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 10 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)) 3.4.4.5 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)) 3.4.4.6 If monitoring demonstrates that the operational requirements in Conditions 3.4.4.2, 3.4.4.3, or 3.4.4.4 are not met, corrective action shall be taken as specified in Conditions 3.4.5 or 3.4.7. If corrective actions are taken as specified, the monitored exceedance is not a violation of the operational requirements in this section. (§60.753(g)) 3.4.5 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)) 3.4.5.1 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 3.4.4.2. 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)) 3.4.5.2 Monitor each well monthly for temperature and nitrogen or oxygen as provided in Condition 3.4.4.3. 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 operational or performance standards. An alternative timeline for correcting the exceedance may be submitted to the Division for approval. (§60.755(a)(5)) Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 11 3.4.6 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)) 3.4.6.1 5 years or more if active; or 3.4.6.2 2 years or more if closed or at final grade. 3.4.7 The following procedures shall be used for compliance with the surface methane operational standard as provided in Condition 3.4.4.4: (§60.755(c)) 3.4.7.1 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)) 3.4.7.2 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)) 3.4.7.3 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)) 3.4.7.4 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 3.4.4.4. (§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 - monitoring shows a third exceedance for the same location, the action specified in Condition 3.4.7.4.e shall be taken, and no further monitoring of that location is required until the action specified in Condition 3.4.7.4.e has been taken. (§60.755(c)(4)(iii)) Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1.20 18 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 12 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 3.4.7.4.b or 3.4.7.4.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 3.4.7.4.c or 3.4.7.4.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 ke 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)) 3.4.7.5 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)) 3.4.8 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)) 3.4.9 Install calibrate, maintain, and operate according to the manufacturer's specifications the following equipment: (§60.756(c)) 3.4.9.1 A heat sensing device, such as an ultraviolet beam sensor or thermocouple, at the pilot light or the flame itself to indicate the continuous presence of a flame. (§60.756(c)(1) 3.4.9.2 A device that records flow to or bypass of the flare. The owner or operator shall either: (§60.756(c)(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(c)(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 Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE1 88 Front Range Landfill, Inc. Front Range Landfill Page 13 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(c)(2)(ii)) 3.4.10 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)) 3.4.11 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)) 3.4.12 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)) 3.4.13 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 3.6.2 of this section requires reports to be submitted every 6 months] 3.4.14 The facility shall keep the following records: 3.4.14.1 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)) 3.4.14.2 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 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)) 3.4.14.3 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)) 3.4.14.4 For the life of the collection system, an up-to-date, readily accessible plot Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 14 map showing each existing and planned collector in the system and providing a unique identification location label for each collector. (§60.758(d)) 3.4.14.5 For at least 5 years, up-to-date, readily accessible records of all collection and control system exceedances of the operational standards in Condition 3.4.4, the reading in the subsequent month whether or not the second reading is an exceedance, and the location of each exceedance. (§60.758(e)) 3.5 In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply 3.5.1 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) 3.5.2 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) 3.5.3 Records of startups, shutdowns, and malfunctions shall be maintained, as required under §60.7 3.5.4 Performance tests shall be conducted as required under §60.8 3.5.5 The flare shall be designed and operated, and records and reports shall be furnished, as required under §60.18 3.6 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.] Operating Permit 97OPWE1 88 : October 1, 2000 Renewed: XXXXX 1, 2€ Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 15 3.6.1 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. 3.6.2 The reports described in 40 CFR 60.757(f) must be submitted every 6 months. 3.6.3 The permittee must comply with the general provisions of this part specified in table 1 of this subpart. Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 16 4. P003 — 550 Gallon Gasoline Tank Parameter Permit Limitation Emission Factor Monitoring Condition Number Method Interval Throughput 4.1 � Recordkeeping P g Monthly Opacity 4.2 Not to Exceed 20% Fuel Restriction NESHAP Subpart CCCCCC 4.3 Work Practice Standard See Condition 4.3 Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B 4.1 The quantity of gasoline processed through this tank shall be monitored and recorded monthly. Monthly records of gasoline processed shall be retained as required by Condition 4.3.1. 4.2 No owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. (Colorado Regulation No. 1, II.A.1). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed based on the type of materials used and the method of operation. 4.3 This source is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of 40 CFR Part 63 Subpart CCCCCC, for Gasoline Dispensing Facilities, 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 CCCCCC published in the Federal Register on 1/24/2011. 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 CCCCCC.] [These requirements have not been adopted into Colorado Regulation No: 8, Part E as of the date of this permit issuance [DA1E], and are therefore not state -enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state -enforceable.] 4.3.1 Upon request by the Administrator, the facility must demonstrate that the tank's monthly gasoline throughput is less than the 10,000 -gallon threshold level (§63.11111(e)). 4.3.2 The facility must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following (§63.11116(a)): 4.3.2.1 Minimize gasoline spills; 4.3.2.2 Clean up spills as expeditiously as practicable; 4.3.2.3 Cover all open gasoline containers and all gasoline storage tank fill -pipes Operating Permit 97OPWE1 88 First Issued: October 1, 2000 Renewed: XXXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 17 with a gasketed seal when not in use; 4.3.2.4 Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators; 4.3.3 The facility is not required to submit notifications or reports, but must have records available within 24 hours of a request by the Administrator to document the gasoline throughput (§63.11116(b)). Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: .XXX.1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 5. P004 — Degreasing Unit Front Range Landfill, Inc. Front Range Landfill Page 18 Parameter Permit Limitation Emission Factor Monitoring Condition Number Method Interval Reg 7, Section X.A — 5.1 See Conditions 5.1 and Transfer and Storage of 5.2 5.2 Waste & Solvents Reg 7, Section X.B — Control Standards 5.3 — 5.8 See Conditions 5.3 through 5.8 Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B. 5.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). (Colorado Regulation No. 7, Section X.A.3) 5.2 Waste or used solvent shall be stored in closed containers unless otherwise required by law. (Colorado Regulation No. 7, Section X.A.4) 5.3 All cold -cleaners shall have a properly fitting cover. (Colorado Regulation No. 7, Section X.B.1.a(i)) 5.3.1 Covers shall be designed to be easily operable with one hand under any of the following conditions (Colorado Regulation No. 7, Section X.B.1.a(ii)): 5.3.1.1 Solvent true vapor pressure is greater than 15 torr (0.3 psia) at 38°C (100°F). (Colorado Regulation No. 7, Section X.B.1.a(ii)(A)) 5.3.1.2 The solvent is agitated by an agitating mechanism. (Colorado Regulation No. 7, Section X.B.1.a(ii)(B)) 5.3.1.3 The solvent is heated. (Colorado Regulation No. 7, Section X.B.1.a(ii)(C)) 5.4 All cold -cleaners shall have a drainage facility that captures the drained liquid solvent from the cleaned parts. (Colorado Regulation No. 7, Section X.B.1.b(i)) For cold -cleaners using solvent which has a vapor pressure greater than 32 ton (0.62 psia) measured at 38°C (100°F) either: 5.4.1 There shall be an internal drainage facility within the confines of the cold -cleaner, so that parts are enclosed under the (closed) cover to drain after cleaning, or if such a facility will not fit within; (Colorado Regulation No. 7, Section X.B.1.b(ii)(A)) 5.4.2 An enclosed, external drainage facility that captures the drained solvent liquid from the cleaned parts. (Colorado Regulation No. 7, Section X.B.1.b(ii)(B)) Operating Permit 97OPWE188 First Issued: October 1, 2000 1 Renewed: 2018 XX� , Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 19 5.5 A permanent, clearly visible sign shall be mounted on or next to the cold -cleaner. The sign shall list the operating requirements. (Colorado Regulation No. 7, Section X.B.1.c) 5.6 Solvent spray apparatus shall not have a splashing, fine atomizing, or shower type action but rather should produce a solid, cohesive stream. Solvent spray shall be used at a pressure that does not cause excessive splashing. (Colorado Regulation No. 7, Section X.B.1.d) For solvents with a true vapor pressure above 32 torr (0.62 psia) at 38°C (100°F), or, for solvents heated above 50°C (120°F), one of the following techniques shall be used: 5.6.1 A freeboard ratio greater than or equal to 0.7. (Colorado Regulation No. 7, Section X.B.1.d(i)) 5.6.2 A water or a non-volatile liquid cover. The cover liquid shall not be soluble in the solvent and shall not be more dense than the solvent and the depth of the cover liquid shall be sufficient to prevent the escape of solvent vapors. (Colorado Regulation No. 7, Section X.B.1.d(ii)) 5.7 The cold -cleaner cover shall be closed whenever parts are not being handled within the cleaner confines. (Colorado Regulation No. 7, Section X.B.2.a) 5.8 Cleaned parts shall be drained for at least 15 seconds and/or until dripping ceases. Any pools of solvent shall be tipped out off the clean part back into the tank. (Colorado Regulation No. 7, Section X.B.2.b) Operating Permit 97OPWE188 : October 1, 2000 Renewed: X.XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 20 SECTION III - Permit Shield 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 21 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., ILC., ILE., 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE1 88 Front Range Landfill, Inc. Front Range Landfill Page 22 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 23 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; (ix) 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. e. Circumvention Clause Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 24 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 25 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 26 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXO( 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 27 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, § III.D.I. 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 970PWE188 First Issued: October 1, 2000 Renewed: )0000C 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 28 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, §§ I., II. 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., ILD., HI. 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 29 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 sped 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 97OPWE188 First Issued: October 1, 2000 Renewed: XX:XX 1.2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 30 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 26. Significant Permit Modifications Front Range Landfill, Inc. Front Range Landfill Page 31 Regulation No. 3, 5 CCR 1001-5, Part C, 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, § II.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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 32 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXX)(X 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 97OPWE188 First Issued: October 1, 2000 Renewed: S;XXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Inspection Information APPENDIX A Inspection Information 1. Directions to Plant: Appendix A Page 1 The facility is located in Weld County in the township of Erie. The property is approximately 15 miles north of Denver, west of I-25, north of State Highway 7, on the east side of Weld County Road 5. 2. Safety Equipment Required: Eye Protection, Hard Hat, Safety Shoes, Hearing Protection, Gloves. 3. Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on YXXX,',2018. 4. 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. Insignificant activities and/or sources of emissions as submitted in the application are as follows: 4.1. An on -site Materials Handling Facility is used as a chemical storage area for any hazardous wastes which are removed and collected from the municipal solid waste stream. Household hazardous wastes are stored in closed containers, which are not opened. Household hazardous wastes removed from the municipal solid waste stream are an insignificant source overall, as defined as the less than 50 lbs/year State limit. 4.2. Miscellaneous landscaping devices. 4.4. Lubricating oil storage for site operations - tank size is 700 gallons. 4.5. 500 -gallon tank for antifreeze storage. 4.6. Diesel fuel storage for site operations - tank compartment sizes are 8,000 and 2,000 gallons. 4.7. Portable emergency generator. 4.8. 550 -gallon waste oil tank 4.9. Miscellaneous routine vehicle and site maintenance materials stored in drums and containers. 4.10. Leachate management activities. 4.11. Pressure washer 4.12. Light plants Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Inspection Information en ac 2 Appendix A Page 2 Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: Appendix B Page 1 (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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) 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 97OPWE188 First Issued: October 1, 2000 Renewed: XX X)O1.2018 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 example, given the various emissions limitations and monitoring requirements to which a source may be 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format Appendix B 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 97OPWE188 First Issued: October 1, 2000 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 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: Front Range Landfill OPERATING PERMIT NO: 97OPWE188 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code 2 Malfunction/Emergency Condition Reported During Period? YES NO YES NO F001 Fugitive particulate emissions P001 Uncollected landfill gas emissions P002 Gas collection and control system P003 550 gasoline storage tank P004 Degreasing unit General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred 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: 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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: Front Range Landfill. OPERATING PERMIT NO: 97OPWE188 REPORTING PERIOD: Is the deviation being claimed as an: (For NSPS/MACT) Did the deviation occur during: OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Appendix B Page 6 Emergency Malfunction N/A Startup Shutdown Malfunction Normal Operation 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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: Appendix B Page 7 Emergency Malfunction XX N/A Startup 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 Shutdown Malfunction Division Code QA: Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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: Front Range Landfill FACILITY IDENTIFICATION NUMBER: 1230079 PERMIT NUMBER: 97OPWE 188 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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: Front Range Landfill OPERATING PERMIT NO: 97OPWE188 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 determine compliance 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 Fugitive particulate emissions P001 Uncollected landfill gas emissions P002 Gas collection and control system P003 550 gasoline storage tank P004 Degreasing unit 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 Operating Permit 97OPWE1 88 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 2 only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. 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. ' 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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-SS-B1 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 2 PSD - PIE - 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 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix F Page 1 APPENDIX F Permit Modifications DATE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: XXXXX 1, 2018 TECHNICAL REVIEW DOCUMENT DRAFT for RENEWAL of OPERATING PERMIT 97OPWE188 Front Range Landfill Weld County Source ID 123-0079 January 2018 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 Front Range Landfill. The previous Operating Permit for this facility was issued on July 1, 2006 and expired on July 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 July 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 Page 1 incorporates and shall be considered to be a combined construction/operating 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 The Front Range Landfill is classified as a municipal solid waste landfill, which falls under the Standard Industrial Classification 4953. This facility is located at 1830 Weld County Road 5, 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. Front Range Landfill is located adjacent to Denver Regional Landfill North, Denver Regional Landfill South, 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 also 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). Page 2 Front Range Landfill emissions are outlined below: Fugitive particulate emissions PM 269.9 148.75 PM10 83.7 45.12 PM2.5 8.7 4.62 Uncollected landfill gas emissions Gas collection and control system emissions VOC 114.5 10.3 CO 4.9 0.3 PM10 4.5 1.1 PM 4.5 1.1 NOX CO 17.9 97.3 4.3 23.6 VOC 6.8 1.6 SO2 4.0 1.0 HAPs Toluene N/A 12.3 Total N/A 19.2 Potential to emit and actual emissions are based on the APENs received on February 28, 2018. Hazardous air pollutant emissions were calculated to show emissions are above 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. Page 3 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 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 in July of 2010 and reported a capacity of 35,768,342 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 Front Range Landfill 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. Compliance Assurance Monitoring (CAM) Applicability The landfill gas collection system is equipped with a flare to control VOC and HAP emissions. The flare is not subject to CAM rules because NSPS WWW was proposed after November 15, 1990. (§64.2(b)(1)(i)) Page 4 NESHAP Subpart CCCCCC There is one gasoline storage tank identified as insignificant activity in the application under the provisions in Colorado Regulation No. 3, Part C, Section II.E.3.fff. However, under the "catch-all" provisions in Regulation No. 3, Part C, Section 11.E, sources that are subject to any federal or state applicable requirement, such as National Emission Standards for Hazardous Air Pollutants (NESHAPs), may not be considered insignificant activities for operating permit purposes. EPA promulgated National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities which apply to this tank; therefore, it can no longer be considered insignificant activity in the operating permit. Although the unit cannot be considered insignificant activity, the tank is still exempt from APEN reporting and minor source construction permit requirements. The applicable requirements were included in the permit. Colorado Regulation No. 7 The facility operates a degreasing unit. Although emissions from this parts washer are below the APEN de minimis level and exempt from APEN reporting and the minor source construction permit requirements, it is subject to specific requirements in Colorado Regulation No. 7, Section X. Therefore, under the "catch-all" provisions in Regulation No. 3, Part C, Section II.E (2nd paragraph) the solvent vat cannot be considered an insignificant activity because it is subject to specific requirements in Regulation No. 7. This source is subject to the state-wide requirements of Regulation No. 7 (Control of Ozone via Ozone Precursors). Regulation 7 Section V prohibits the disposal of VOCs by evaporation or spillage unless RACT is applied. This requirement is included in Condition 29(c) of Section IV, General Permit Conditions. IV. Discussion of Modifications Made Source Requested Modifications • July 1, 2010 modification request o Updated source information to reflect single source classification with Denver Regional Landfill North, Denver Regional Landfill South, and Timberline Energy. o Updated Responsible official and facility contact person as requested. o Section I ■ Updated permit language to reflect change in attainment Page 5 area as requested. o Section II • Condition 1.2.2 was removed as requested because of repetitive requirements in 1.2.1. • Conditions 1.2.6 and 1.2.8 were removed as requested to be more consistent with recently issued permits. ■ Condition 2.1 was updated to be more consistent with current division permit language. This change supersedes the requested language modification. • Condition 2.2 was removed as requested to be consistent with the petroleum contaminated soil memo #12-01. • Condition 2.3 could not be changed to annual record keeping because this would not be consistent with current division record keeping requirements of waste acceptance. • Condition 2.4 (Subpart WWW language) was updated to be more consistent with current division permit language. This change supersedes the requested language modification. • Condition 2.5 (Subpart A language) was updated to be more consistent with current division permit language. This change supersedes the requested language modification. o Appendix A ■ Insignificant activities list was updated as requested. • July 20, 2012 modification request o Section II • Construction permit 11WE1680 was added to the permit as requested. Applicable requirements can be found in Condition 3 of the permit. • March 31, 2016 modification request o Section II • Waste acceptance was increased to 2,230,000 tons per year as requested. This change required the facility take fugitive dust emission limits, which were previously not required by Page 6 the permit. The modification also required the facility to water roads more frequently to stay within minor modification limits. The VOC emission limit also increased but all emission changes were within minor modification requirements. • February 28, 2018 modification request o Section II • Landfill VOC emissions were increased below the significance level to account for the increase acceptance of petroleum contaminated soils. There was no change in design capacity or waste acceptance rate, but the facility will now use the considerable quantities of PCS method for calculating emissions found in PS Memo #12.01. Other Modifications 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 • Landfill fugitive particulate emissions • Removed fugitive emission weekly checks, off property transfer, and vehicle speed limit requirements to be more Page 7 consistent with recently issued permits. • Split landfill emissions in to two sections: o Uncollected landfill gas emissions • 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. • Added landfill capacity limit from the most recently submitted Design Capacity Report. o Gas collection and control system • Updated NSPS WWW language to current approved division format and requirements. • Added the 500 gallon gasoline tank and requirements to the permit. • Added the degreasing unit and requirements to the permit. 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. Page 8 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 97OPWE188 APPLICANT: Front Range Landfill REVIEW ENGINEER: Jayson Ellis AIRS ID #: 123/0079 DATE: July 24, 2018 SOURCE DESCRIPTION Front Range Landfill 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 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. Front Range Landfill is located adjacent to Denver Regional Landfill North, Denver Regional Landfill South, and the Timberline Energy facility and are considered to be a single stationary source. This facility is located at 1830 Weld County Road 5, 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. FACILITY EMISSION SUMMARY Fugitive particulate emissions PM 269.9 148.75 PM10 83.7 45.12 PM2.5 8.7 4.62 Uncollected landfill gas emissions Gas collection and control system emissions VOC 114.5 10.3 CO 4.9 0.3 PM10 4.5 1.1 PM 4.5 1.1 NOX 17.9 4.3 CO 97.3 23.6 VOC 6.8 1.6 SO2 4.0 1.0 HAPs Toluene N/A 12.3 Total N/A 19.2 PERMIT 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. Landfill fugitive particulate emissions: Waste acceptance was increased to 2,230,000 tons per year as requested. This change required the facility take fugitive dust emission limits, which were previously not required by the permit. The modification also required the facility to water roads more frequently to stay within minor modification limits. The VOC emission limit also increased but all emission changes were within'minor modification requirements. Flare emissions: The flare was not modified and emissions remain unchanged. Landfill gas emissions: Landfill VOC emissions were increased below the significance level to account for the increase acceptance of petroleum contaminated soils. There was no change in design capacity or waste acceptance rate, but the facility will now use the considerable quantities of PCS method for calculating emissions found in PS Memo #12.01 Gasoline tank: The facility has one 500 gallon gasoline storage tank. The quantity of gasoline throughput shall be monitored and recorded monthly. The emissions are below APEN de minimis levels and the tank is APEN and Construction Permit exempt. The tank is subject the NESHAP Subpart CCCCCC and all federal requirements can be found in the Title V permit. Degreasing unit: Although emissions from this parts washer are below the APEN de minimis level and exempt from APEN reporting and the minor source construction permit requirements, it is subject to specific requirements in Colorado Regulation No. 7, Section X. Therefore, under the "catch-all" provisions in Regulation No. 3, Part C, Section II.E (2nd paragraph) the solvent vat cannot be considered an insignificant activity because it is subject to specific requirements in Regulation No. 7. INSIGNIFICANT ACTIVITIES A list of insignificant activities is included in the draft Operating Permit. RECETVEL . JUL 2 2010 APCD Stationar} June 29, 2010 Project No. 0601-606-11-07-01 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 Front Range Landfill, Inc. 1830 Weld County Rd 5 Erie, Co 80516 303-828-9400 Re: Operating Permit Minor Modification and Renewal Application Permit Number 97OPWE188 Facility ID: 1230079 (was 1230246) Front Range Landfill — Weld County, Colorado Dear Mr. King: Please find enclosed the Operating Permit Minor Modification and Renewal Application for the Front Range Landfill (facility) located in Weld County, Colorado. The facility currently operates under Permit Number 97OPWE188, which was first issued October 1, 2000 and last revised January 6, 2010. For the purposes of complying with federal regulations, the Division recently determined that Front Range Landfill, Denver Regional Landfill South, and Denver Regional Landfill North are a single contiguous site per the administrative permit amendment response letter dated January 6, 2010. Relevant Title V Application Forms are provided in Attachment 1. The requested revisions are discussed in detail in Attachment 2. The proposed revisions meet the minor modification criteria, and as such, the facility requests the Division to process this modification application under Colorado Air Quality Control Commission (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 facility 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 AQCC Regulation No. 3 Part C, Section X.D.6, a revised APEN for this minor modification 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. C: (DOCUMENTS AND SE77!NGSUEFFBU.SA CRAMENTOILOCAL SETTINGS(TEMPORAR Y INTERNET FILESIOLKSIL TR-CDPHE (TO BE PRINTED ON WCI LETTERHEAD).DOC Jim King June 29, 2010 Page 2 In conjunction with minor modifications to the operating permit, please update the existing construction permit for the facility. In addition to the operating permit minor modification, please renew Operating Permit 97OPWE188. 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, Front Ran e Landfill, Inc. f Burrier istrict 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 SETTINGSVEFFBU.SACRAMENTOILOCAL SETTINGSITEMPORARYINTERNET FILESIOLK?ILTR-CDPHE (TO BE PRINTED ON WC/ LETTERHEAD).DOC P1 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 mailing address Name Street or Route City, State, Zip Coale Front Range Landfill 6855 South Havana, Suite 300 Centennial, Colorado, 80112 2. Facility location (No P.O. Box) Street Address 1830 Weld County Road 5 City,County, Zip Code Erie, CO 80516 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) Front Range Landfill, Inc. 1830 Weld County Road 5 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: 26- 4442980 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 X Renewal 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 PM 10 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. Determination of Contiguous Site for Denver Regional Landfill North, Denver Regional Landfill South, and Front Range Landfill — August 25, 2009 0: WASTE CONNECTIONS'IFRONTRANGE TETLE VRENEWAL 0BE ACILITY/D FORA2000-100.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: 88DE 189 May 15, 1989 Fugitive Dust Sept 1, 1992 Grandfathered Feb 2, 1972 Incinerator Gravel Pit Smith Boiler O:',WASTE. CONNECTIONSV'RONT RANGE:TITLE CRENEWAL 20/0',FAC'1L/TY ID FORM 2000-/00.DOC 2 INSIGNIFICANT ACTIVITIES (FORM 2000-102B AND FORM 2000-700) • Operating Permit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and Environment Air Pollution Control Division FORM 2000-102B Rev 06-95 Facility Name: Front Range Landfill Facility Identification Code: CO 1 2 3 0 0 7 9 NOTE: The operating permit must be prepared and submitted on forms 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. O 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). O 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. • Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). O 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. • Storage tanks of capacity < 40,000 gallons of lubricating oils. ❑ 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. ❑ 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, or4-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). ❑ 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. O 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: Front Range Landfill 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 • An on -site Materials Handling Facility is used as a chemical storage area for any hazardous wastes which are removed and collected from the municipal solid waste stream. Household hazardous wastes are stored in closed containers, which are not opened. Household hazardous wastes removed from the municipal solid waste stream are an insignificant source overall, as defined as the less than 50 lbs/year State limit. • Miscellaneous landscaping devices. • Lubricating oil storage for site operations — tank size is 700 gallons • 500 -gallon tank for antifreeze storage. • Diesel fuel storage for site operations — tank compartment sizes are 8,000 and 2,000 gallons. • Portable emergency generator. • 550 -gallon waste oil tank. • Miscellaneous routine vehicle and sie maintenance materials stored in drums and containers. • Leachate management activities. (k.6Vns(e(bmrec/ioos%romRange�'T ieVRenemni?0i0!Sbppiemenmlbjo2000-70(troc 1 RESPONSIBLE OFFICIAL CERTIFICATION (FORM 2000-800) Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Front Range Landfill 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 ❑ Form 2000-200. Stack Identification O Form 2000-300, Boiler or Furnace Operation O Form 2000-301, Storage Tanks . O 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 O Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: O Form 2000-400, Miscellaneous O Form 2000-401, Condensers ❑ Form 2000-402, Adsorbers ❑ Form 2000-403, Catalytic or Thermal Oxidation ❑ Form 2000-404, Cyclones/Settling Chambers . O Form 2000-405, Electrostatic Precipitators O Form 2000-406, Wet Collection Systems ❑ Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number ofThis 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 . O Form 2000-507, Recordkeeping O Form 2000-508, Other Methods 0.' WASTE CONNECTIONS FRONTRANGE.T/TLE NRENEWAL 2010112O 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 ❑ 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 O 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 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 § 25-7122.1, C.R.S. Printed or Typed Name Jeff Burner Title District Manager Si a Date Signed Z$ 2x1O P:ILFGFPROJECTSIWASTE CONNECTIONSFFRONT RANGEIT1TLE NRENEWAL 201015O CERT FORM 2000-800.DOC 2 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Front Range Landfill CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 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 formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) 1 I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. O I certify that the facility described in this air pollution permit application is fully in compliance with all applicable 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 false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7122.1, C.I.S. Printed or Typed Name i " v l Title D1.S rT CT 0 414.hkat.ie Signa Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-Bl 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 P:ILFGIPROJECISIWASTE CONNECTIONSIFRONT RANG£ITTTLE PIREN£WAL 1010tRO CERT FORM1000-800.DOC 3 ATTACHMENT 2 MINOR MODIFICATION REVISIONS MINOR MODIFICATION REVISIONS Cover Page For the purposes of complying with federal regulations, the Division determined that Front Range Landfill, Denver Regional Landfill South, and Denver Regional Landfill North are a single contiguous site in a letter dated August 25, 2009. Please revise the Facility ID Number on the cover page to 1230079. 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 (303) 968-9508 Facility Contact Person: Jeff Burlier District Manager (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 projected life of the landfill noted in this condition is 35 years, but depending on actual waste acceptance and settling of waste -in -place the projected life of the landfill may change. Please remove this text to avoid frequent operating permit revisions. 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 CONNECT/ONSI RONT RANGE TITLE I/RENEWAL 20/O1TEXT.DOC6r0/2010 1 3. Prevention of Serious Deterioration (PSD), Condition 3.1 Please update the first and third paragraphs to reflect the 8 -hour ozone nonattainment designation for the area. Suggested text for this condition is included with Attachment 6 (Suggested Draft Permit). Section II — Specific Permit Terms Conditions 1.2.2 Condition 1.2.2 repeats the requirements in Condition 1.2.1. As such, it is requested that Condition 1.2.2 be removed. Conditions 1.2.6 and 1.2.8 The facility's solid waste permit and certificate of designation regulates the placement of daily cover and when the facility is required to cease operation due to wind. As such, it is requested that Conditions 1.2.6 and 1.2.8 be removed. Condition 2. P001 — Landfill Gas Generation; The site requests that the Division revise the table under Condition 2 as indicated in Attachment 6 (Suggested Draft Permit) and explained below. Please update the emission limit for VOC from Landfill Gas to reflect the revised APEN in Attachment 3 and supporting emission calculations. 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. The attached APEN does not reference the existing AIRS ID Number because it is unclear how the Division will identify emission units which have overlapping AIRS ID Numbers because of the redesignated Facility ID Number. Please remove Condition 2.2 and associated emission limitations, emission factors, and monitoring intervals. The removal of Condition 2.2 is discussed under a separate heading below. Please revise the monitoring interval associated with Condition 2.3 to reflect the revised text of Condition 2.3 discussed below. Weaver Boos Consultants, LLC—Southwest WASTE C'ONNE'CTIONS FRONT RANGE TITLE FRENEWAL ?0l0 TF17:UOC6/30/?010 2 Condition 2.1 Please revise the third and fourth sentences of the Condition 2.1 as exemplified in Attachment 6 (Suggested Draft Permit). The third sentence of Condition 2.1 states that VOC emissions are a set portion of the NMOC emissions. Please revise this condition to state that the VOC concentration as a set portion of the NMOC concentration of landfill gas. Please revise the fourth sentence to remove references to annual calculation of NMOC and HAP emissions because there are no emission rate limits associated with emissions of NMOC or HAP. The emission limits associated with Condition 2.1 apply to landfill fugitive VOC emissions, which is based on NMOC concentration and includes HAP. As such, separate annual NMOC and HAP emission calculations are not needed. Condition 2.2 It is requested that this condition be deleted from the site's operating permit. Petroleum contaminated materials are just one of many waste materials receive at the site. Once placed in the landfill, this waste material becomes part of the landfill and overall landfill emissions. Therefore, the volatile organic emissions from the petroleum contaminated materials are represented and accounted for when calculating VOC emissions from the landfill. It should also be noted that the acceptance of petroleum contaminated material is common practice at other Colorado sites, and separate provisions have not been required in other Title V permits. Condition 2.3 Please revise the second sentence and remove third sentence as indicated in Attachment 6 (Suggested Draft Permit). The waste acceptance records are used to calculate the VOC emissions using the quantity of materials accepted annually. However, the second and third sentences in the condition require monthly and 12 -month rolling records. It is unclear what purpose limiting the 12 -month rolling waste acceptance serves, when the VOC emissions resulting from disposed waste are calculated annually based only on the annual waste acceptance record. Condition 2.4.1.3 Please remove the second sentence of Condition 2.4.1.3 to match NSPS requirements. The annual NMOC emission report is no longer applicable to the facility per 40 CFR §60 Subpart WWW. Weaver Boos Consultants, LLC—Southwest O:' WASTE CONNEC'TIONS FRONT RANGE TITLE VRENEWAL 2010i TEAT DOC6/30/2010 3 Condition 2.4.4 Please remove Condition 2.4.4 to match NSPS requirements. The annual NMOC emission report is no longer applicable to the facility per 40 CFR §60 Subpart WWW. Condition 2.5.3 Please remove the Condition 2.5.3 as indicated in Attachment 6 (Suggested Draft Permit). The facility is an existing facility with ongoing operations, and as such, the initial startup and construction notifications will not apply. Appendix A — Inspection Information List of Insignificant Activities: Please revise the appendix to update insignificant sources/activities as listed 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 WASTE CONNECTIONS FRONT RANGE-T%TLE NRENLWAL ?0 10‘ TEXT DOC6/30/2010 4 ATTACHMENT 3 REVISED APEN AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Finished Products: Permit Number: 97OPWE188 Facility Equipment ID: Landfill Gas Generation Section 01— Administrative Information Company Name: Front Range Landfill, Inc. [Leave blank unless APCD has already assigned a permit # & AIRS 1D] Emission Source AIRS ID: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Source Name: Front Range Landfill Source Location: 1830 Weld County Road 5 Portable Source Home Base: Mailing Address: Person To Contact: E-mail Address: Erie, Colorado 6855 South Havana, Suite 300 Centennial, Colorado Jeff Burrier jeffbu@wcnx.org Section 03 — General Information For existing sources, operation began on: Normal Pours of Source Operation: General description of equipment and purpose: NAICS, or SIC Code: 4953 County: Weld Elevation: 5250 Feet ZIP Code: 80112 Phone Number: 303-968-9508 Fax Number: / / 1996 Section 02 — Requested Action (check applicable request boxes) ❑ Request for NEW permit or newly reported emission source ❑ Request PORTABLE source permit ® Request MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ® Change permit limit ❑ Transfer of ownership ❑ Other O Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory O Additional Info. & Notes: Update 5 -Year APEN term without change to permit limits or previously reported emissions The Division determined that Front Range Landfill will be designated with Facility ID Number 1230079. The existing AIRS ID for the source must be updated to avoid conflicting with AIRS ID numbers already assigned to Facility ID 1230079 For new or reconstructed sources, the projected startup date is: 24 hours/day 7 days/week 52 weeks/year Landfill Gas Generation / / Will this equipment be operated in any NAAQS nonattainment area? (http://www.cdphe.state.co.us/ap/attainmaintain.html) Section 04 — Processing/Manufacturing Equipment Information & Material Use Description of equipment': Manufacturer: Model No.: ® Yes Serial No.: No Don't know Description (For Data Year) Actual Level Annual Requested Permitted Level (Specify Units) Design Process Rate (Specify Units/Hour) Other Process:''.. 'If additiona space is required, please attach a separate list of equipment, materials and throughputs. 2Requested values will become permit limitations. Requested level should consider process growth over the next five years. 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/downloadforms.html Application status: http://www.cdphe.state.co.us/ap/ss/sspcpt.html ® Check box to request copy of draft permit prior to issuance. ❑ Check box to request copy of draft permit prior to public notice. FORM APCD-200 Page 1 of 3 GeneralAPEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Permit Number: 97OPWE188 Emission Source AIRS ID: / 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) Operator Stack 1D No. Base Elevation (feet) Discharge Height Above Ground Level (Feet) Temp. (°F); Flow Rate (ACFM) °' Velocity (ft/sec) Moisture (%) Horizontal Datum (Nf1Ci27, NAD83, WGS84) UTM Zone (12 or 13) UTM Basting or Longitude, (meters or degrees) UTM Northing or Latitude (meters or degrees). Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) Direction of outlet (check one): • Vertical n Vertical with obstructing raincan I-1 unrivnntA1 n nn..r„ rl n*i .- mo—..:r.oN. Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = Section 06 — Combustion Equipment & Fuel Consumption Information Company equipment Identification No.: Manufacturer: ❑ Other: Length (inches) _ Model: Width (inches) = Serial No.: • Fuel Type Yl? Design Input Rate . (106 Btu/hr) Actual Level (For Data Year) Annual Requested Permitted Levee (Specify Units) Fuel Heating Value (Indicate: ' Btu/lb, Btu/gal, Btu/SCF) .Percent by Weight ' Seasonal ' Fuel Use (% of Annual Use) Sulfur Ash "' Dec -Feb Mar -May Jun -Aug Sep -Nov d . Requested level snoulu 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. ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant TSP Control Device Description Primary "? Secondary Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor Uncontrolled Basis; Units 2015 Actual Calendar Year: Emissions3 Uncontrolled (Tons/Year) Controlled (Tons/Year) Requested Permitted Emissions4 Uncontrolled (Tons/Year) Controlled (Tons/Year) Estimation; Method or Emission Factor Source PM 10 PM2.s SOx NOx VOC See Attached Calculations 16.9 44.2 CO AP -42 / LandGEM 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. 4If Requested Permitted Emissions is left blank, the APCD will calculate emissions based on the information supplied in sections 03 - 07. Page 2 of 3 GeneralAPEN.doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. egally .A,uthor1zed, to Supply Data Jeff Burner Name,of LegallyAt thonzed;P District Manager e print) k W-MitteligadialWr 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: 97OPWE188 Front Range Landfill, Inc. 1830 Weld County Rd. 5 Jeff Burlier jeffbu@wcnx.org AIRS ID Number: County: Weld Phone Number: 303-968-9508 Fax Number: Zip Code: 80516 Chemical Abstract Service (CAS) Number Chemical Name Reporting BIN g Control 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 AP -42 _ 312.2 107-06-2 1,2 — Dichloroethane A Attachment 5 AP -42 68.6 107-13-1 Acrylonitrile A Attachment 5 AP -42 567.9 71-43-2 Benzene A Attachment 5 AP -42 250.9 75-15-0 Carbon Disulfide A Attachment 5 AP -42 74.7 74-87-3 Chloromethane A Attachment 5 AP -42 102.4 106-46-7 Dichlorobenzene A Attachment 5 AP -42 52.2 75-09-2 Dichloromethane A Attachment 5 AP -42 2,053.7 7783-06-4 Hydrogen Sulfide A Attachment 5 AP -42 2,045.6 74-93-1 Methyl Mercaptan A Attachment 5 AP -42 203.4 127-18-4 Perchloroethylene A Attachment 5 AP -42 1,045.8 108-88-3 Toluene C Attachment 5 AP -42 6,075.2 75-01-4 Vinyl Chloride A Attachment 5 AP -42 775.7 1330-20-7 Xylenes C Attachment 5 AP -42 2,154.0 75-71-8 Dichlorodifluoromethane C Attachment 5 AP -42 3,209.6 Reporting Scenario (1, 2 or 3): 1 Calendar Year for which Actual Data Applies: 2015 Form Revision Date: December 4, 2006 S' tu'- of Person Legally Authorized to Supply Data Jeff Burrier Date 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 ATTACHMENT 4 LANDGEM V3.02 MODEL FRL_Iandgem-v302-Rev. 1.xls 6/30/2010 LandGEM Landfill Gas Emissions Model U.S. Envirotunental Protection Agency Office of Research and Development National Risk Tvlanagement Research Laboratory ,=., •• aicl Clean Air Technology Center (CATC) Research Triangle Park, North Carolina Summary Report Landfill Name or Identifier: Front Range Landfill Date: Wednesday, June 30, 2010 Description/Comments: C&D waste is considered inert and is not accounted for in the model input waste acceptance. Waste input values only include waste deemed to be biodegradable. About LandGEM: ' n First Order Decomposition Rate Equation: = 1 { „ �a e ' ) �.CH4 a i=1 j=Q.1 1 0 Where, QcHa = annual methane generation in the year of the calculation (m3 /year) i = 1 -year time increment M; = mass of waste accepted in the ith year (Mg) n = (year of the calculation) - (initial year of waste acceptance) ti = age of the j"' section of waste mass M; accepted in the i"' year j = 0.1 -year time increment (decimal years, e.g., 3.2 years) k = methane generation rate (year -1) Lo = potential methane generation capacity (m3 /Mg ) 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 (CM) regulations, and other guidance regarding landfill gas emissions and control technology requirements can be found at http://www.epa.gov/ttnatw0l/landfill/landflpg.html. LandGEM is considered a screening tool — 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 FRL_Iandgem-v302-Rev. 1.xls 6/30/2010 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, Lo NMOC Concentration Methane Content GASES / POLLUTANTS SELECTED Gas / Pollutant #1: Gas / Pollutant #2: Gas / Pollutant #3: Gas / Pollutant #4: WASTE ACCEPTANCE RATES Total landfill gas Methane Carbon dioxide NMOC 1996 2040 2040 No 0.020 100 595 50 megagrams year m3/Mg ppmv as hexane by volume Year Waste Accepted Waste -In -Place (Mg/year) (short tons/year) (Mg) (short tons) 1996 58,656 64,522 0 0 1997 274,010 301,411 58,656 64,522 1998 291,186 320,305 332,666 365,933 1999 114,486 125,935 623,852 686,237 2000 179,357 197,293 738,338 812,172 2001 150,959 166,055 917,695 1,009,465 2002 149,611 164,572 1,068,654 1,175,519 2003 152,976 168,274 1,218,265 1,340, 092 2004 166,255 182,881 1,371,241 1,508,365 2005 187,560 206,316 1,537,496 1,691,246 2006 187,749 206,524 1,725,056 1,897,562 2007 196,790 216,469 1,912,805 2,104,086 2008 214,632 236,095 2,109,595 2,320,555 2009 145,124 159,636 2,324,227 2,556,650 2010 0 0 2,469,351 2,716,286 2011 483,972 532,370 2,469,351 2,716,286 2012 769,716 846,688 2,953,323 3,248,656 2013 785,111 863,622 3,723,040 4,095,344 2014 800,813 880,894 4,508,151 4,958,966 2015 816,829 898,512 5,308,964 5,839,860 2016 833,166 916,482 6,125,793 6,738,372 2017 849,829 934,812 6,958,959 7,654,855 2018 866,826 953,508 7,808,788 8,589,667 2019 884,162 972,579 8,675,614 9,543,175 2020 901,846 992,030 9,559,776 10,515,754 2021 919,882 1,011,871 10,461,622 11,507,784 2022 938,280 1,032,108 11,381,504 12,519,655 2023 957,046 1,052,750 12,319,784 13, 551,763 2024 976,187 1,073,805 13,276,830 14,604, 513 2025 995,710 1,095,281 14,253,017 15,678,318 2026 1,015,625 1,117,187 15,248,727 16,773,600 2027 1,035,937 1,139,531 16,264,351 17,890, 787 2028 1,056,656 1,162,321 17,300,289 19, 030,317 2029 1,077,789 1,185,568 18,356,944 20,192,639 2030 1,099,345 1,209,279 19,434,733 21,378,207 2031 1,121,332 1,233,465 20,534,078 22,587,486 2032 1,143,758 1,258,134 21,655,409 23,820,950 2033 1,166,633 1,283,297 22,799,168 25,079,084 2034 1,189,966 1,308,963 23,965,801 26,362,381 2035 1,213,765 1,335,142 25,155,767 27,671,344 REPORT -2 FRL_landgem-v302-Rev. 1.xls 6/30/2010 WASTE ACCEPTANCE RATES (Continued) Year Waste Accepted Waste -In -Place (Mg/year) (short tons/year) (Mg) (short tons) 2036 1,238,041 1,361,845 26,369,532 29,006,486 2037 1,262,801 1,389,082 27,607,573 30,368,330 2038 1,288,058 1,416,863 28,870,375 31,757,412 2039 1,313,819 1,445,201 30,158,432 33,174,275 2040 1,248,009 1,372,810 31,472,251 34,619,476 2041 0 0 32,720,260 35,992,286 2042 0 0 32,720,260 35,992,286 2043 0 0 32,720,260 35,992,286 2044 0 0 32,720,260 35,992,286 2045 0 0 32,720,260 35,992,286 2046 0 0 32,720,260 35,992,286 2047 0 0 32,720,260 35,992,286 2048 0 0 32,720,260 35,992,286 2049 0 0 32,720,260 35,992,286 2050 0 0 32,720,260 35,992,286 2051 0 0 32,720,260 35,992,286 2052 0 0 32,720,260 35,992,286 2053 0 0 32,720,260 35,992,286 2054 0 0 32,720,260 35,992,286 2055 0 0 32,720,260 35,992,286 2056 0 0 32,720,260 35,992,286 2057 0 0 32,720,260 35,992,286 2058 0 0 32,720,260 35,992,286 2059 0 0 32,720,260 35,992,286 2060 0 0 32,720,260 35,992,286 2061 0 0 32,720,260 35,992,286 2062 0 0 32,720,260 35,992,286 2063 0 0 32,720,260 35,992,286 2064 0 0 32,720,260 35,992,286 2065 0 0 32,720,260 35,992,286 2066 0 0 32,720,260 35,992,286 2067 0 0 32,720,260 35,992,286 2068 0 0 32,720,260 35,992,286 2069 0 0 32,720,260 35,992,286 2070 0 0 32,720,260 35,992,286 2071 0 0 32,720,260 35,992,286 2072 0 0 32,720,260 35,992,286 2073 0 0 32,720,260 35,992,286 2074 0 0 32,720,260 35,992,286 2075 0 0 32,720,260 35,992,286 REPORT -3 FR L_Iandgem-v302-Rev. 1.xls 6/30/2010 Results Year Total landfill gas Methane (Mg/year) (m 3/year) (av ft^3/min) (Mg/year) (m 3/year) (av ft"3/min) 1996 0 0 0 0 0 0 1997 2.904E+02 2.325E+05 1.562E+01 7.756E+01 1.163E+05 7.812E+00 1998 1.641E+03 1.314E+06 8.830E+01 4.384E+02 6.571E+05 4.415E+01 1999 3.050E+03 2.442E+06 1.641E+02 8.147E+02 1.221E+06 8.205E+01 2000 3.557E+03 2.848E+06 1.914E+02 9.500E+02 1.424E+06 9.568E+01 2001 4.374E+03 3.503E+06 2.353E+02 1.168E+03 1.751E+06 1.177E+02 2002 5.035E+03 4.032E+06 2.709E+02 1.345E+03 2.016E+06 1.354E+02 2003 5.676E+03 4.545E+06 3.054E+02 1.516E+03 2.272E+06 1.527E+02 2004 6.321E+03 5.061E+06 3.401E+02 1.688E+03 2.531E+06 1.700E+02 2005 7.019E+03 5.620E+06 3.776E+02 1.875E+03 2.810E+06 1.888E+02 2006 7.808E+03 6.252E+06 4.201E+02 2.086E+03 3.126E+06 2.101E+02 2007 8.583E+03 6.873E+06 4.618E+02 2.293E+03 3.436E+06 2.309E+02 2008 9.387E+03 7.517E+06 5.051E+02 2.507E+03 3.758E+06 2.525E+02 2009 1.026E+04 8.219E+06 5.522E+02 2.742E+03 4.109E+06 2.761E+02 2010 1.078E+04 8.632E+06 5.799E+02 2.879E+03 4.316E+06 2.900E+02 2011 1.057E+04 8.461E+06 5.685E+02 2.822E+03 4.230E+06 2.842E+02 2012 1.275E+04 1.021E+07 6.861E+02 3.406E+03 5.106E+06 3.431E+02 2013 1.631E+04 1.306E+07 8.776E+02 4.357E+03 6.530E+06 4.388E+02 2014 1.987E+04 1.591E+07 1.069E+03 5.309E+03 7.957E+06 5.346E+02 2015 2.345E+04 1.877E+07 1.261E+03 6.263E+03 .9.387E+06 6.307E+02 2016 2.702E+04 2.164E+07 1.454E+03 7.219E+03 1.082E+07 7.270E+02 2017 3.061E+04 2.451E+07 1.647E+03 8.177E+03 1.226E+07 8.236E+02 2018 3.422E+04 2.740E+07 1.841E+03 9.139E+03 1.370E+07 9.204E+02 2019 3.783E+04 3.029E+07 2.035E+03 1.010E+04 1.515E+07 1.018E+03 2020 4.146E+04 3.320E+07 2.231E+03 1.107E+04 1.660E+07 1.115E+03 2021 4.510E+04 3.611E+07 2.427E+03 1.205E+04 1.806E+07 1.213E+03 2022 4.876E+04 3.905E+07 2.624E+03 1.302E+04. 1.952E+07 1.312E+03 2023 5.244E+04 4.199E+07 2.821E+03 1.401E+04 2.100E+07 1.411E+03 2024 5.614E+04 4.496E+07 3.021E+03 1.500E+04 2.248E+07 1.510E+03 2025 5.986E+04 4.793E+07 3.221E+03 1.599E+04 2.397E+07 1.610E+03 2026 6.361E+04 5.093E+07 3.422E+03 1.699E+04 2.547E+07 1.711E+03 2027 6.737E+04 5.395E+07 3.625E+03 1.800E+04 2.698E+07 1.812E+03 2028 7.117E+04 5.699E+07 3.829E+03 1.901E+04 2.849E+07 1.915E+03 2029 7.499E+04 6.005E+07 4.035E+03 2.003E+04 3.002E+07 2.017E+03 2030 7.884E+04 6.313E+07 4.242E+03 2.106E+04 3.157E+07 2.121E+03 2031 8.272E+04 6.624E+07 4.451E+03 2.210E+04 3.312E+07 2.225E+03 2032 8.664E+04 6.937E+07 4.661E+03 2.314E+04 3.469E+07 2.331E+03 2033 9.058E+04 7.253E+07 4.874E+03 2.420E+04 3.627E+07 2.437E+03 2034 9.457E+04 7.572E+07 5.088E+03 2.526E+04 3.786E+07 2.544E+03 2035 9.858E+04 7.894E+07 5.304E+03 2.633E+04 3.947E+07 2.652E+03 2036 1.026E+05 8.219E+07 5.522E+03 2.742E+04 4.109E+07 2.761E+03 2037 1.067E+05 8.547E+07 5.743E+03 2.851E+04 4.274E+07 2.871E+03 2038 1.109E+05 8.878E+07 5.965E+03 2.962E+04 4.439E+07 2.983E+03 2039 1.151E+05 9.213E+07 6.190E+03 3.073E+04 4.607E+07 3.095E+03 2040 1.193E+05 9.552E+07 6.418E+03 3.186E+04 4.776E+07 3.209E+03 2041 1.231E+05 9.857E+07 6.623E+03 3.288E+04 4.929E+07 3.312E+03 2042 1.207E+05 9.662E+07 6.492E+03 3.223E+04 4.831E+07 3.246E+03 2043 1.183E+05 9.471E+07 6.363E+03 3.159E+04 4.735E+07 3.182E+03 2044 1.159E+05 9.283E+07 6.237E+03 3.097E+04 4.642E+07 3.119E+03 2045 1.136E+05 9.099E+07 6.114E+03 3.035E+04 4.550E+07 3.057E+03 REPORT -4 ATTACHMENT 5 EMISSION CALCULATIONS ACTUAL EMISSION CALCULATIONS (5 -YEAR MAXIMUM) LANDFILL GAS GENERATION ACTUAL (5 -YEAR MAXIMUM) EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO Required: Determine the potential fugitive emissions from the landfill using the 5 -year maximum landfill gas (LFG) generation predicted by the EPA LFG generation model. Estimates for VOCs and HAPs 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. References: 1. AP -42 equations used to calculate emissions of VOCs and HAPs: 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, 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: UM, = (Qp 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. Molecular weight and concentration of NMOCs (as hexane) and VOCs in LFG are: MWNMOC CNMOC = MWvoc = Cvoc = 3. Conversion Factors: 86.18 595 86.18 232.05 g/g-mol (hexane) ppmv (as hexane) g/g-mol (hexane) ppmv 35.315 ft3 = I 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 (Default from EPA AP -42) (Assumed as equal to NMOC) (39% of NMOC conc. per Operating Permit) O:'W tste Connections From Range Title VRenewal 2010Actual Emission Coles - LEG Gen landfill -Fug Page 1 of 3 Weaver Boos Consultants, LLC 6/30/2010 LANDFILL GAS GENERATION ACTUAL (5 -YEAR MAXIMUM) EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO Assumptions: 1. Estimated maximum CH4 generation rate for the next five years predicted by the EPA's LandGEM v3.02 model is: QcH4 = 9,386,987 m3/yr 631 scfm CH4 1,261 scfm LFG 2. The following conditions are assumed in calculating the emissions of VOCs using Equation 4 provided in Reference I. P = 1 atm R = 8.205E-05 m3-atm/gmol-K T = 298 K Calculations: 1. VOC Emissions: 1) Based on the methane generation (Assumption 1), calculate the VOC emission rate in m3/yr generated by the landfill using Equation 3 (Reference 1): Qvoc = 2 QCH4 Cvoc / 1,000,000 QCH4 = Cvoc = 9,386,987 m3/yr 232.05 ppmv Qvoc = 4,357 m3/yr 2) Calculate the mass emission rate of VOC in kg/yr emitted as fugitives from the landfill using Equation 4 (Reference - 1) and Assumption 2: UMvoc = (Qvoc MWvoc P) / (1,000 R T) Qvoc = 4,357 m3/yr MWvoc = 86.18 g/g-mol P = 1 atm R = 8.205E-05 m3-atm/gmol-K T = 298 K UMvoc = 15,355 kg/yr 3) Convert emissions to tons/yr using conversion factor (Reference 3): UMvoc = 16.92 tons/yr 3.86 lbs/hr a Waste Connections Fran, Range Title VRenewal 20/RActual Emission (-ales - L/'G Gen landfill -Fug Page 2 of 3 Weaver Boos Consultants, LLC 6/30/2010 NON CRITERIA REPORTABLE AIR POLLUTANTS LANDFILL GAS GENERATION ACTUAL (5 -YEAR MAXIMUM) EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO Estimated 5 -year maximum landfill CH4 generation rate: 1,1,2,2 - Tetrachloroethane 1,2 - Dichloroethane (ethylene dichloride) Acrylonitrile Benzene Carbon Disulfide Chloromethane (methyl chloride) Dichlorobenzene d Dichioromethane (methylene chloride) Hydrogen Sulfide Methyl Mercaptan Perchloroethylene (tetrachloroethylene) Toluene Vinyl Chloride Xylenes Dichlorodifluoromethane e 79-34-5 107-06-2 107-13-I 71-43-2 75-15-0 74-87-3 106-46-7 75-09-2 7783-06-4 74-93-I 127-18-4 108-88-3 75-01-4 1330-20-7 75-71-8 A A A A A A A A A A A C A C C 9,386,987 m3/yr 167.85 98.96 53.06 78.11 76.13 50.49 147.0 84.94 34.08 48.11 165.83 92.13 62,5 106.16 120.91 1.10 0.41 6.33 1.90 0.58 1.20 0.21 14.30 35.50 ),50 3.73 39.00 7.34 12.00 15.70 0.036 0.008 0.065 0.029 0.009 0.012 0.006 0.234 0.234 0.023 0.119 0.694 0.089 0.246 0.366 0.156 0.034 0.284 0.125 0.037 0.051 0.026 1.027 1.023 0.102 0.523 3.038 0.388 1.077 ° 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. 1.605 312.2 68.6 567.9 250.9 74.7 102.4 52.2 2,053.7 2,045.6 203.4 1,045.8 6,075.2 775.7 2,154.0 3,209.6 0.025 0.025 0.025 0,025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.500 0,025 0.500 0.500 (k 1Waslc Connections T'roni Rangel2ide Wieneu'al 2L/101AcPoal Emission Cellos - LEG Gen Speeialed-rug Page 3 of 3 Weaver Boos Consultants, LLC-Southwest 6/3 0/20 10 POTENTIAL EMISSION CALCULATIONS LANDFILL GAS GENERATION POTENTIAL EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO Required: Determine the potential fugitive emissions from the landfill using the maximum landfill gas (LFG) generation predicted by the EPA LFG generation model over the full site life. Estimates for VOCs and HAPs 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. References: 1. AP -42 equations used to calculate emissions of VOCs and HAPs: 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: Q, = emission rate of pollutant p, m3/yr QCH4 = CH4 generation rate, 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: UM, = (QP 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 MW, = 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. Molecular weight and concentration of NMOCs (as hexane) and VOCs in LFG are: MWNMOC = CNMOC = MWvoc = Cvoc = 3. Conversion Factors: 86.18 g/g-mol (hexane) 595 ppmv (as hexane) 86.18 232.05 g/g-mol (hexane) ppmv 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 (Default from EPA AP -42) (Assumed as equal to NMOC) (39% of NMOC conc. per Operating Permit) o:. Waste Connecrions Front Range.Title V Renewal 2010'Potentinl Emission Colo' - LFG Gen land/ill-Fug Page 1 of 4 Weaver Boos Consultants, LLC 6/30/2010 LANDFILL GAS GENERATION POTENTIAL EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO Assumptions: 1. Estimated maximum CH4 generation rate predicted by the EPA's LandGEM v3.02 model over the full site life is: QCH4 = 49,285,897 3,311 6,623 m3/yr scfm CH4 scfm LFG The site has submitted a GCCS design plan and will install a GCCS upon approval. As per AP -42, Section 2.4.4.2, an average of 75% of LFG generated is commonly assumed to be collectable and controllable. The remainder of the LFG is released as fugitive emissions. For determining the maximum potential emission rates, the calculations will conservatively assume a collection efficiency of 50%. (i) QLFG-FUG = QLFG,mae (S0%) QLFG-FUG = 3,311 49,285,897 (1i) QCH4-FUG= QCH4,max (50°/0) QCH4-FUG= 1,656 24,642,948 scfm of LFG m3/yr of LFG scfm of CH4 m3/yr of CH4 2. The following conditions are assumed in calculating the emissions of VOCs using Equation 4 provided in Reference 1. P = 1 atm R = 8.205E-05 m3-atm/gmol-K T = 298 K Calculations: 1. VOC Emissions: 1) Based on the fugitive methane generation (Assumption 1), calculate the VOC emission rate in m3/yr generated by the landfill using Equation 3 (Reference 1): Qvoc = 2 QCH4 CVGC / 1,000,000 QCH4 = 24,642,948 m3/yr Cvoc = 232.05 ppmv Qvoc = 11,437 m3/yr U: Waste ConnectionsFront Range•Ttde VRenewal 20/0.Potentinl Emission Cola - LFG Gen lnndli9-flip Page 2 of 4 Weaver Boos Consultants, LLC 6/30/2010 LANDFILL GAS GENERATION POTENTIAL EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO 2) Calculate the mass emission rate of VOC in kg/yr emitted as fugitives from the landfill using Equation 4 (Reference 1) and Assumption 2: UMvoc = (Qvoc MWvoc P) / (1,000 R T) Qvoc = 11,437 m3/yr MWvoc = 86.18 g/g-mol P = 1 atm R = 8.205E-05 m3-atm/gmol-K T = 298 K UMvoc = 40,310 kg/yr 3) Convert emissions to tons/yr using conversion factor (Reference 3): UMvoc = 44.42 tons/yr 10.14 lbs/hr Q: •iVasie Conneciions•Front Range •l irle VRenewal 2010Poreniiol Emission Colo - LEG Gen landfill -Fug Page 3 of 4 Weaver Boos Consultants, LLC 6/30/2010 NON CRITERIA REPORTABLE AIR POLLUTANTS LANDFILL GAS GENERATION POTENTIAL EMISSION CALCULATIONS FRONT RANGE LANDFILL - WELD COUNTY, COLORADO Maximum potential landfill fugitive CH4 generation rate: 24,642,948 m3/yr is Ce z g,, e :, 11YQ' 8 pfo. �Y: ��'l.1tt1[1�itUS 1,1 - Dichloroethane (ethylidene dichloride) 1,1 - Dichloroethene (vinylidene chloride) 1,2 - Dichloroethane (ethylene dichloride) 1,2 - Dichloropropane (propylene dichloride) Acrylonitrile Benzene Carbon 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 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 B A A A A A A A A A A C C C A B A A C C A C C 167.85 98.97 96.94 98.96 112.99 53.06 78.11 76.13 112.56 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 1.10 2.40 0.20 0.41 0.18 6.33 1.90 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 0.094 0.120 0.010 0.02 I 0.010 0.170 0.075 0.022 0.014 0.03 I 0.016 0.615 0.246 0.247 0.288 0.613 0.096 0.061 0.313 1.821 0.186 0.232 0.646 0.962 0.410 0.527 0.043 0.090 0.045 0.745 0.329 0.098 0.062 0.134 0.069 2.696 1.076 1.084 1.262 2.685 0.422 0.267 1.373 7.974 0.817 1.018 2.827 4.213 819.6 1,054.3 86.1 180.1 90.3 1,490.8 658.8 196.0 124.9 268.9 137.0 5,391.5 2,151,1 2,167.6 2,524.7 5,370.2 844.7 533.9 2,745.6 15,948.8 1,633.1 2,036.3 5,654.6 8,426.0 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 " 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. 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. U: 1 Wash• Connections:/', -Inn RageOi,le INiene wal 20 rov'n,enind C7n,.c,,i,m Coles - LFG Gen spcc,a,ecl-li,g Page 4 of 4 Weaver Boos Consultants, LLC-Southwest (,/3U/2010 ATTACHMENT 6 SUGGESTED DRAFT PERMIT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Front Range Landfill OPERATING PERMIT NUMBER FACILITY ID: . 791230246 ISSUE DATE: July 1, 2006 EXPIRATION DATE: July 1, 2011 MODIFICATIONS: See Appendix F of Permit 97OPWE 188 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: PLANT SITE LOCATION: Front Range Landfill, Inc. 1830 Weld County Road 5 Erie, CO 80516 Front Range Landfill 1830 Weld County Road 5 Erie, CO 80516 INFORMATION RELIED UPON Operating Permit Application Received: And Additional Information Received: September 21, 2004 Nature of Business: Municipal Solid Waste Disposal Primary SIC: 4953 RESPONSIBLE OFFICIAL Name: r� Phil Rivard Title: .. Region Vice President Phone: 303 708 8359 FACILITY CONTACT PERSON Name: Title: Phil Rivard Region Vice President Phone: 303 708 8359 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: October - March, April - September Semi -Annual Monitoring Report: November 1, 2006 & May 1, 2007 and subsequent years Annual Compliance Period: October 1 to September 30 Annual Compliance Certification: November 1, 2006 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 Peanut # 97OPWE188 SECTION I - General Activities and Summary 1 Permitted Activities Front Range Landfill, Inc. Front Range Landfill Page 1 1.1 This source is a municipal solid waste disposal facility accepting non -hazardous solid waste (as defined in 6 CCR 1007-2) and a projected life of 35 years. The landfill began accepting waste in 1996. Decomposing waste encapsulated within the landfill produces a gas that is primarily composed of methane and carbon dioxide. Emissions of non -methane organic compounds (NMOC), which include, Volatile Organic Compounds (VOC) and Hazardous Air Pollutants (HAP), also result from the decomposition of solid waste placed in the landfill. Fugitive particulate emissions are emitted from the following landfill activities: material transfer to and from storage piles, disturbed areas, wind erosion of storage piles, waste dumping, and vehicle traffic on unpaved roads. The facility is located in Erie, Weld County, Colorado. The area in which the plant operates is designated as attainment for all criteria pollutants excluding ozone. This facility is located in the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A. 16 lb. The 8 -hr Ozone ea has been'* designated as nonattalrlxr�ent axea with `respect to the hour ozone There are no affected estates within 50 miles of the plant. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park and Rawah Wilderness Area. 12 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. 13 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 H) from the following construction permits: 91WE766. 14 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(g), 14 and 18 (as noted). 15 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 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 2 2. Alternative Operating Scenarios 21 The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 21.1 No separate operating scenarios have been specified. 3. Prevention of Significant Deterioration 3.1 This facility is located in an area designated attainment for all pollutants exc1ud ozone. 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). 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. This facility is located in the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A 16 Ib The $ hr ©zone Control Area has been designated as a nonattaiiirnent area with respect to the 8- hour ozone 32 Operating Permits 99OPWE215 & 03OPWE254, which cover Denver Regional Landfill North and Denver Regional Landfill South, are to be considered in conjunction with this Operating Peiiuit for purposes of determining the applicability of NANSR or PSD review regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based upon the information provided by the applicant, this facility is 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 Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 • Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 5 days of the date such plan or revision is requested; provided, however, that the division, in its discretion, may where appropriate establish a different time period for submittal, taking into consideration such factors as the duration of the operation of the source or activity, the significance and nature of the emissions, and the relative complexity of the operation and applicable control methods. 1.1.4 Each control plan shall include all available practical methods which are technologically feasible and economically reasonable and which reduce, prevent and control fugitive particulate emissions from the source or activity into the atmosphere. For those materials, equipment, services or other resources (such as water for abatement and control purposes) which are likely to be scarce at any given time, an alternative control method must be included in the control plan. Any source required to submit a control plan may ask for a "control plan conference" with the division, and if so requested the division shall hold such a conference for the purpose of advising what types of control measures and/or operating procedures will meet the requirements of Regulation No. 1, III.D. 12 The source shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions (Colorado Regulation No. 1, Section III.D. 1 .a). The source shall certify semi-annually that all appropriate measures have been taken to minimize fugitive emissions. The following particulate emissions control measures shall be used for enforcement purposes on the particulate emission producing sources, as required by Colorado Regulation No. 1 (Construction Permit 91WE766, as modified under the provisions of Section I, Condition 1.3): 12.1 Fugitive particulate emissions from land clearing, topsoil and overburden removal and disturbed areas shall be controlled by watering or use of chemical suppressants as necessary. 12.2 Active material stockpiles shall be watered as necessary to control fugitive particulate 1.2.3 Inactive stockpiles and closed landfill areas shall be revegetated and/or watered as necessary to control fugitive particulate emissions. 124 Vehicle speed on unpaved roads and disturbed areas shall not exceed 25 m.p.h. Speed limit signs shall be posted. 12.5 Fugitive particulate emissions from haul roads shall be controlled by watering or other suitable methods as needed. 126 After placement of waste at the active face, the wastes will be compacted and covered within 24 hours with a minimum of 6 inches of daily soil cover or alternative daily cover. Operating Pemut 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 6 1.2.7 The size of the working face shall be reduced to control fugitive dust emissions during windy days. 128 A wir veleci y measuring device shall be installed in the facility. Landfill operation shall cease during periods when high wind warnings are verified. High wind warnings are defined as sustained winds of 40 miles per hour or greater or gusts of 55 miles per hour or greater that are expected to persist for one hour or longer. Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 2 P001 - Landfill Gas Generation Front Range Landfill, Inc. Front Range Landfill Page 7 Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission Limits 2.1 VOC from Landfill Gas: 444 /11.7 tons/year EPA's Landfill Gas Emissions Model (LandGEM) or EPA AP -42 2.4 Recordkeeping & Calculation Annual 2.2 VOC from Petroleum Mass Balance & Recordkeeping & Monthly, Sampling Calculation Annual Contaminated Soils: 5.0 tons/year Waste Acceptance Rate 2.3 1,500,000 tons/year Recordkeeping Monthly Annual Standards of Performance for Municipal Solid Waste Landfills 2.4 40 CFR Part 60, Subpart WWW As Defined NSPS General Provisions 2.5 Subject b NSPS General Provisions 21 Emissions of air pollutants shall not exceed the limits listed above. Compliance with the annual limits shall be determined on an annual basis (rolling 12 -month totals not required) using the most recent version of the EPA's Landfill Gas Emissions Model (LandGEM) or the calculation method from AP -42 2.4. VOC concentration emissions shall be 39% of the total NMOC concentration emissions determined. Annual emission calculations of VOC, NMOC, and HAPs, along with the waste acceptance rate records shall be maintained for Division inspection upon request (Construction Permit 91 WE766, as modified under the provisions of Section I, Condition 1.3). 2.2 The VOC emissions from petroleum contaminated soils, when used as daily cover, shall not exceed the limit in the table above. The permittee shall calculate emissions from contaminated materials received by using a mass balance based on the concentration of contaminants and the quantity of materials accepted (Colorado Construction Permit 91 WE766) 22.1 The permittee shall sample incoming contaminated soils semi annually to determine VOC content for use in calculations. Alternatively, the analysis of soils provided by the generator may be used. 2.2.2 The amount of petroleum contaminated soil accepted, and the amount of petroleum contaminated soil used as daily cover shall be recorded on a monthly basis and used in the emission calculation. 2.3 The waste acceptance rate shall not exceed the limitations stated above (Construction Permit 91WE766, as modified under the provisions of Section I, Condition 1.3). Waste acceptance shall Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 8 be recorded anixally monthly. A new rolling twelve month total of waste acceptance will be determined each month using the previous twelve months data. 2.4 This source 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: 24.1 Control of MSW landfill emissions is required at each MSW landfill meeting the following conditions: 2.4.1.1 The landfill has accepted waste at any time since November 8, 1987, or has additional design capacity available for future waste deposition; 2.4.1.2 The landfill has a design capacity greater than or equal to 2.5 million megagrams or 2.5 million cubic meters; and 2.4.1.3 The landfill has a nonmethane organic compound (NMOC) emission rate of 50 megagrams per year or more. The NMOC emission rate will be submitted to the Division in the initial emission rate report and also on an annual basis in an annual emissions report. 2.4.2 Landfills meeting the above conditions shall comply with 40 CFR §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 must be approved by the Division and meet the following requirements: 2.4.21 An open flare designed and operated in accordance with the parameters established in 40 CFR §60.18 (General Provision); or 2.4.22 A control system designed and operated to reduce NMOC by 98 weight percent; or 2.4.23 An enclosed combustor designed and operated to reduce the outlet NMOC concentration to 20 parts per million as hexane by volume, dry basis at 3 percent oxygen, or less. 24.3 Each owner or operator of an MSW landfill having a design capacity equal to or greater than 2.5 million megagrams or 2.5 million cubic meters is subject to Part 70 permit requirements. 2A.A1 An emission report must be submitted annually to the Division according to /10 CFR §60.752 & 60.757. 2.4.5 The facility shall comply with the following requirements of 40 CFR: 2.4.5.1 §60.753 Operational standards for collection and control systems 2.4.5.2 §60.754 Test methods and procedures 2.4.5.3 §60.755 Compliance provisions Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 9 2.4.5.4 §60.756 Monitoring of operations 2.4.5.5 §60.757 Reporting requirements 2.4.5.6 §60.758 Recordkeeping requirements 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. (40 CFR §60.12) 253 Written notification of construction and initial startup dates shall be submitted to the Division as required under /10 CFR §60.7 25.4 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR §60.7. Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 Air Pollution Control Division Colorado Operating Permit Inspection Information APPENDIX A Inspection Information 1. Directions to Plant: Appendix A Page 1 The facility is located in Weld County in the township of Erie. The property is approximately 15 miles north of Denver, west of I-25, north of State Highway 7, on the east side of Weld County Road 5. 2. Safety Equipment Required: Eye Protection, Hard Hat, Safety Shoes, Hearing Protection, Gloves. 3. Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on July 10, 1997 with the source's Title V Operating Permit Application. 4. 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. Insignificant activities and/or sources of emissions as submitted in the application are as follows: 4.1. An on -site Materials Handling Facility is used as a chemical storage area for any hazardous wastes which are removed and collected from the municipal solid waste stream. Household hazardous wastes are stored in closed containers, which are not opened. Household hazardous wastes removed from the municipal solid waste stream are an insignificant source overall, as defined as the less than 50 lbs/year State limit. 42 Miscellaneous landscaping devices. '13. Four propane heaters of less than de minimis size. Each building has a small tank (approx. 1000 gallons or less). 4.4. Lubricating oil storage for site operations - tank size is 700 gallons. 4.5. 500 -gallon tank for antifreeze storage. 4.6. Diesel fuel storage for site operations - tank compartment sizes are 8,000 and 2,000 gallons. 4.7. Portable emergency generator. 55U gallon waste oil tank MiscelYaneous routine vehicle and„ site maintenance materials stored in drums and,co'ntainers_ eacliate management actin his Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 David Cousins Project Engineer ZiIIMAYER CONBLTLTANTSS LLC SCVILTTI-IIATESM 6420 SOUTHWEST BLVD, SUITE 206 FORT WORTH, TEXAS 76109 PHONE: 817.735.9770 FAX: 817.735.9775 www.weaverboos.com July 19, 2012 Project No. 0601-606-50-07-01 Mr. Matt Burgett Colorado Department of Public Health & Environment Air Quality Control Division — Stationary Sources Building B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Operating Permit Modification Facility Identification Code: 1230079 Operating Permit: 97OPWE188 Front Range Landfill — Weld, Colorado Dear Mr. Burgett: Chicago, IL Naperville, IL Springfield, IL South Bend, IN St. Louis, MO Columbus, OH Denver, CO Fort Worth, TX Clermont, FL Grand Rapids, MI Portland, OR On behalf of Front Range Landfill, Inc., please find enclosed the Operating Permit Modification for the Front Range Landfill located in Weld County, Colorado. The facility is currently authorized under Operating Permit Number 97OPWE188, which was issued in October 2000, renewed July 2006, and revised January 6, 2010. An application to renew the operating permit was submitted on June 29, 2010, which is currently under review by APCD. Please update the operating permit renewal application, specifically Attachment 1, with the attached, revised forms. The updated forms reflect the addition of a landfill gas utility flare approved under Construction Permit 11WE1680 issued January 25, 2011. 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. Sincerely, Weaver Boos Consultants, LLC Archana Nagara Air Quality Manager Attachment: Operating Permit Modification cc: Brian Karp, Front Range Landfill, Inc. Jeff Burner, Front Range Landfill, Inc. Matt K. Stutz, P.E., Weaver Boos Consultants, LLC Q:IWASTE CONNECTIONSIFRONT RANGEITTTLE 1112012 MODIFICATIONICDPHE CVRLTLDOC ATTACHMENT OPERATING PERMIT MODIFICATION 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 Front Range Landfill mailing address Street or Route PO Box 320 City, State, Zip Code Erie, CO 80516 2. Facility location Street Address 1830 Weld County Road 5 (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.) Front Range Landfill, Inc. 1830 Weld County Road 5 Erie, CO 80516 4. Responsible Name official Title Telephone Brian Karp District Manager 303-673-9431 5. Permit contact person Name Title (If Different than 4) Telephone Brian Karp District Manager 303-673-9431 6. Facility SIC code: 4 9 5 3 7. Facility identification code: 1230079 8. Federal Tax I. D. Number: 26 4442980 9. Primary activity of the operating establishment: Municipal Solid Waste Landfill 10. Type of operating permit 0 New ID Modified 0 Renewal 11. Is the facility located in a "nonattainment" area: El Yes 0 No If "Yes", check the designated "non -attainment" pollutant(s): 0 Carbon Monoxide LI Ozone 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. 0 PM10 0 Other (specify) 1 Operating Permit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and Environment Air Pollution Control Division Facility Name: Front Range Landfill Facility Identification Code: CO 1230079 FORM 2000-102B Rev 06-95 NOTE: The operating permit must be prepared and submitted on forms 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. 0 (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. 0 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). 0 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). 0 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. ❑x Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. El Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). 0 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. 0 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. 0 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. ❑X 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. El 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. 2 0 Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. ❑x 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). 0 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. 0 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. 0 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 3 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-600 Rev 06-95 1. Facility name: Front Range Landfill 2. Facility identification code: CO 1230079 3. Stack identification code: 013 4. Unit identification code: 5. Unit material description: 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached n' Please reference the Construction Permit Application (11WE1680) dated May 20, 2011 and approved on September 7, 2011 for calculations and equipment information. Pollutant CAS Common or Generic Pollutant Name A* Sion Allowable OR Potential to emit Q r i ` easureffien. # Quantity Measurement Units U nlin 7647-01-0 Hydrogen Chloride 's NIA NIA 2.056 TPY 75-09-2 Dichloromethane NIA` '.. NIA 0.036 TPY v. -fie dWxy>-*4� £� ^a0. "4 i'$,'y: i } �4! 4 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Front Range Landfill 2. Facility identification code: CO 1230079 3. Stack identification code: 013 4. Unit identification code: 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached El Please reference the Construction Permit Application (11WE1680) dated May 20, 2011 and approved on September 7, 2011 for calculations and equipment information. Air pollutant Potential to emit Maximum allowable uan ......._... U TPY Particulates (TSP) N/A N/A PM -10 4.5 TPY Nitrogen oxides 17.9 TPY Volatile organic compounds 0.5 TPY Carbon monoxide 97.2 TPY Lead N/A N/A Sulfur dioxide 4.0 TPY Total reduced sulfur N/A N/A Reduced sulfur compounds N/A N/A Hydrogen sulfide N/A N/A Sulfuric Acid Mist N/A N/A Fluorides N/A N/A Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) 5 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE SUPPLEMENTAL INFORMATION FORM 2000-700 09-94 1. Facility name: Front Range Landfill 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 An on -site Materials Handling Facility is used as a chemical storage area for any hazardous wastes which are removed and collected from the municipal solid waste stream. Household hazardous wastes are stored in closed containers, which are not opened. Household hazardous waste removed from the municipal solid waste stream are an insignificant source overall, as defined as the less than 50 lbs/year State limit. Miscellaneous landscaping devices. Lubricating oil storage for site operations - tank size is 700 gallons. 500 -gallon tank for antifreeze storage. Diesel fuel storage for site operations — tank compartment sizes are 8,000 and 2,000 gallons. Portable emergency generator. 550 -gallon waste oil tank. Miscellaneous routine vehicle and site maintenance materials stored in drums and containers. Leachate management activities. 6 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Front Range Landfill Facility Identification Code: 1230079 I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS 09-94 FORM 2000-800 This application contains the following forms: © Form 2000-100, Facility Identification 0 Form 2000-101, Facility Plot Plan © Forms 2000-102, -102A, and -102B, Source and Site Descriptions IL EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing 0 Form 2000-200, Stack Identification 0 Form 2000-300, Boiler or Furnace Operation 0 Form 2000-301, Storage Tanks 0 Form 2000-302, Internal Combustion Engine 0 Form 2000-303, Incineration 0 Form 2000-304, Printing Operations 0 Form 2000-305, Painting and Coating Operations 0 Form 2000-306, Miscellaneous Processes 0 Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: 0 Form 2000-400, Miscellaneous 0 Form 2000-401, Condensers 0 Form 2000-402, Adsorbers 0 Form 2000-403, Catalytic or Thermal Oxidation 0 Form 2000-404, Cyclones/Settling Chambers 0 Form 2000-405, Electrostatic Precipitators 0 Form 2000-406, Wet Collection Systems 0 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, 0 Form 2000-500, Compliance Certification - Monitoring and Reporting 0 Form 2000-501, Continuous Emission Monitoring 0 Form 2000-502, Periodic Emission Monitoring Using Portable Monitors 0 Form 2000-503, Control System Parameters or Operation Parameters of a Process 0 Form 2000-504, Monitoring Maintenance Procedures 0 Form 2000-505, Stack Testing 0 Form 2000-506, Fuel Sampling and Analysis 0 Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 7 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 1 0 Form 2000-602, Facility Hazardous Air Pollutants 0 Form 2000-603, Facility Criteria Air Pollutants B Form 2000-604, Applicable Requirements and Status of Emission Unit 0 Form 2000-605, Permit Shield Protection Identification 0 Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 0 Form 2000-607, Plant -Wide Applicable Requirements 0 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 inquiry, I certify that the statements B. CERTIFICATION OF FACILITY box only) in its entirety and, based on information and belief formed after reasonable and information contained in this application are true, accurate and complete. COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one described in this air pollution permit application is fully in compliance with all described in this air pollution permit application is fully in compliance with all except for the following emissions unit(s): © I certify that the facility applicable requirements. 0 I certify that the facility applicable requirements, (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7122.1, C.R.S. Printed or Typed Name Brian Karp Title District Manager Signature .` ,-.v.. Date Signed 7/9//2. 8 Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Front Range Landfill Facility Identification Code: CO 1230079 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS c A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information certify that the statements and information contained in this application B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE only) and belief formed after reasonable inquiry, I are true, accurate and complete. -ONLY CONDITIONS (check one box is fully in compliance with all application is fully in compliance with all unit(s): makes any false material statement, application is guilty of a misdemeanor and E2 I certify that the facility described in this air pollution permit application applicable requirements. 0 I certify that the facility described in this air pollution permit applicable requirements, except for the following emissions (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., representation, or certification in, or omits material information from this may be punished in accordance with the provisions of § 25-7122.1, C.R.S. Printed or Typed Name Brian Karp Title District Manager Signature �' (�\, Date Signed 7/4[/2 - SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 9 Weaver Consultants A Group March 30, 2016 Mr. Matthew Burgett 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 Front Range Landfill Facility ID: 1230076, Permit Number 970PWE188 Project No. 0601-606-50-51-00 Dear Mr. Burgett: RECEIVED win 1 2016 APcU Slalior a Sources On behalf of our client, Front Range Landfill, Inc., please find the enclosed request for a Title V Operating Permit Minor Modification for the Front Range Landfill. The facility operates under Title V Operating Permit No. 970PWE188, which was issued in October 2000, renewed July 2006, and revised January 2010. The facility also operates under Construction Permit No. 11WE1680, which was issued in June 2015. The updated forms reflect the waste acceptance increase request for approval by the Colorado Department of Public Health and Environment. The increase of refuse acceptance requires authorization from the Air Quality Control Division due to an increase in the potential volatile organic compounds (VOC) and hazardous air pollutants (HAP) emission rates. The supporting emission rate calculations are included in Attachment 3. An Air Pollutant Emission Notice (APEN) reporting the increase in the potential VOC and HAP emission rates from the landfill, along with the APEN filing fee, are included in Attachment 4. The supporting emission calculations are included in Attachments 3 and 4. air A copy of this submittal has been placed in the site operating record for this facility. During the course of your revigr4r, if you should have any questions or comments regarding this submittal, please do not hesit'e to contact us at 720-529-0132. We appreciate the Air Pollution Control Division's assistance;With this, and request an expedited written approval of this minor permit modification. U. •L Sincerely, Weaver Consultants Group Melissa Green Project Manager Attachments cc: Dan Gudgel, Waste Connections, Inc. r RI John Briest P.E. Principal F:lADMIN\WC\FRONT RANGEIAPEN\TITLE V PERMIT MOD 2016-03\COVER LETTER.DOCX 7340 E. Caley Avenue • Suite 110 • Centennial, Colorado 80111 • 720.529.0132 • wcgrp.com • Offices Nationwide FACILITY IDENTIFICATION (FORM 2000-100) Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division FACILITY IDENTIFICATION FORM 2000-100 Rev 06-95 SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name mailing address Street or Route City, State, Zip Code Front Range Landfill P.O. Box 320 Erie, CO 80516 2. Facility location Street Address (No P.O. Box) City,County, Zip Code 1830 Weld County Road 5 Erie, CO 80516 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) Front Range Landfill, Inc. 1830 Weld County Road 5 Erie, Colorado 80516 4. Responsible Name official Title Telephone Dan Cudgel District Manager (303)673-9431 Dan Gudgel 5. Permit contact person Name Title (If Different than 4) Telephone District Manager (303)673-9431 6. Facility SIC code: 4 9 5 3 7. Facility identification code: 1230076 8. Federal Tax I. D. Number: 26-4442980 9. Primary activity of the operating establishment: Municipal Solid Waste Landfill 10. Type of operating permit 0 New ❑x Modified 0 Renewal 11. Is the facility located in a "nqi attainment" area: 0 Yes 0 No Jr If "Yes", check the designated "non -a t inment" pollutant(s): t �4 0 Carbon Monoxide [ FIOzone 0 PM10 0 Other (specify) 12. List all (Federal and State) *pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what,Aunit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. -2 Title V Operating Permit No. 970PWE188 Construction Permit No. 11 WE 1680 1 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-600 Rev 06-95 1. Facility name: Front Range Landfill 2. Facility identification code: CO 1230076 3. Stack identification code: 002 4. Unit identification code: F001 5. Unit material description: Landfill 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached ❑x Pollutant CAS Common or Generic Pollutant Name Allowable OR Potential to emit Quantity Measurement Units 71-55-6 1,1,1 - Trichloroethane M n 285.8 lb/yr 79-34-5 1,1,2,2-Tetrachloroethane , t; 824.1 lb/yr 75-34-3 1,1 - Dichloroethane A 1060.2 lb/yr 107-13-1 Acrylonitrile Eft 1492.1 lb/yr 71-43-2 Benzene , 662.4 lb/yr 75-00-03 Chloroethane t 2„ h 374.4 lb/yr 74-87-3 Chloromethane 270.4 lb/yr 75-09-2 Dichloromethane w _ f 5308.0 lb/yr 75-18-3 Dimethyl Sulfide Y" 2163.1 lb/yr 100-41-4 Ethylbenzene 2179.7 lb/yr 110-54-3 Hexanl y, 2538.9 lb/yr 7783-06-4 iI •7' Hydrogon Sulfide - � ., a ', i m 5 -a 5476.3 lb/yr 108-10-1 Methyltsobutyl Ketone 849.4 lb/yr 74-93-1 Methyl Oercaptan 536.9 lb/yr 127-18-4 PerchlOloethylene 2738.8 lb/yr 108-88-3 ' Toluene 16038.1 lb/yr 79-01-6 Trichloroethylene 1642.3 lb/yr 75-01-4 Vinyl Chloride 2036.5 lb/yr 1330-20-7 Xylenes 5686.3 lb/yr 2 EMISSION UNIT CRITERIA AIR POLLUTANTS (FORM 2000-601) Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: Front Range Landfill 2. Facility identification code: CO 1230076 3. Stack identification code: 001 4. Unit identification code: F001 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached El Air pollutant ►ctual Potential to emit Maximum allowable U TPY Particulates (TSP) PM -10 N/A N/A N/A N/A Nitrogen oxides N/A N/A Volatile organic compounds 73.0 (Landfill) TPY Carbon monoxide N/A N/A Lead N/A N/A Sulfur dioxide N/A N/A Total reduced sulfur N/A N/A Reduced sulfur compounds N/A N/A Hydrogen sulfide Sulfuric Acid Mist N/A N/A N/A N/A Fluorides N/A N/A Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) 3 RESPONSIBLE OFFICIAL CERTIFICATION (FORM 2000-800) Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health Air Pollution Control Division Facility Name: -Front Range Landfill Facility Identification Code: 1230076 I. ADMINISTRATION 09-94 This application contains the following forms: 0 Form 2000-100, Facility Identification 0 Form 2000-101, Facility Plot Plan Forms 2000-102, -102A, and -102B, Source and Site Descriptions H. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing 0 Form 2000-200, Stack Identification 0 Form 2000-300, Boiler or Furnace Operation 0 Form 2000-301, Storage Tanks 0 Form 2000-302, Internal Combustion Engine 0 Form 2000-303, Incineration 0 Form 2000-304, Printing Operations 0 Form 2000-305, Painting and Coating Operations 0 Form 2000-306, Miscellaneous Processes 0 Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: n „ '' 0 Form 2000-400, Miscellaneous 0 Form 2000-401, Condensers 0 Form 2000-402, Adsorbers 0 Form 2000-403, Catalytic or Thermal Oxidation 0 Form 2000-404, Cyclones/Settling Chambers 0 Form 2000-405, Electrostatic Precipitators 0 Form 2000-406, Wet Collection Systems 0 Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE R ; o.r,; DEMONSTRATION �� Total Number of This Form This application contains the following forms !ii: (one for each facility boiler, printing operation,',Reporting G %! al 0 Form 2000-500, Compliance Certification - Monitoring and 0 Form 2000-501, Continuous Emission Monitoring 0 Form 2000-502, Periodic Emission Monitoring Using Portable Monitors 0 Form 2000-503, Control System Parameters or Operation Parameters of a Process 0 Form 2000-504, Monitoring Maintenance Procedures 0 Form 2000-505, Stack Testing 0 Form 2000-506, Fuel Sampling and Analysis 0 Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 4 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 1 © Form 2000-601, Emission Unit Criteria Air Pollutants 1 ❑ Form 2000-602, Facility Hazardous Air Pollutants ❑ Form 2000-603, Facility Criteria Air Pollutants o 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 inquiry, I certify that the statements B. CERTIFICATION OF FACILITY box only) in its entirety and, based on information and belief formed after reasonable and information contained in this application are true, accurate and complete. COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one described in this air pollution permit application is fully in compliance with all described in this air pollution permit application is fully in compliance with all except for the following emissions unit(s): © I certify that the facility applicable requirements. ■ I certify that the facility applicable requirements, a ,a Y 1 (list all ion -complying units) I.4 WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, ata omits material information from this application is guilty of a misdemeanor and may be punished in accordance;with the provisions of § 25-7122.1, C.R.S. Printed or Typed Name Dan Gudgel Title District Manager Signature i'' Date Si ed 3/2"//C ATTACHMENT 2 MODIFICATION REQUESTED TO THE OPERATING PERMIT Modification Requested to the Operating Permit Section II — Specific Permit Term Permit Conditions 2.1 and 2.3 It is requested that the limit for landfill volatile organic compounds (VOC) emissions be increased from 41.7 tons/year to 73.0 tons/year. A gas collection and control system (GCCS) collection efficiency of 60% is being assumed; therefore, 40% of the emissions are deemed fugitive. There is no change to the design capacity, but the landfill would like to increase the yearly waste accepted, which requires the amendment to the VOC emissions limit. A default nonmethane organic compound (NMOC) concentration of 956 ppmv as hexane was used in calculating the increase in landfill VOC emissions. It is also requested that the limit for waste accepted at the landfill be increased from 1,500,000 tons/year to 3,000,000 tons/year. Parameter; Current Emission Limit Proposed Emission Limit Emission Limits VOC from Landfill Gas: 41.7 tons/year VOC from Landfill Gas: 73.0 tons/year Note: Increase in VOC Emissions is less than 40 tons. F\ADMINIWC\FRONT RANGE\APEN\TITLE V PERMIT MOD 2016-03\ATT 2.1.DOCX Weaver Consultants Group 3/30/2016 1 OPERATING PERMIT REPLACEMENT PAGE Air Pollution Control Division Colorado Operating Permit Permit # 97OPWE188 Front Range Landfill, Inc. Front Range Landfill Page 7 2. P001 - Landfill Gas Generation; Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission Limits 2.1 VOC from Landfill Gas: 11.7 tons/year EPA's Landfill Gas Emissions Model (LandGEM) or EPA AP -42 2.4 Recordkeeping & Calculation Annual 73.0 tons/year 2.2 VOC from Petroleum Contaminated Soils: 5.0 tons/year Mass Balance & Sampling Recordkeeping & Calculation Monthly, Annual Waste Acceptance Rate 2.3 1,500,000 tons/year fr ' ,�'A� -r Recordkeeping Monthly 3,000,000 tons/year Standards of Performance for Municipal Solid Waste Landfills 2 4 ; ' , ; [- ' _'{< 40 CFR Part 60, Subpart WWW As Defined NSPS General Provisions 2.5 ti t � sr ` r G `' F Subject to NSPS General Provisions 2.1 Emissions of air pollutants shall not exceed the limits listed above. Compliance with the annual limits shall be determined on an annual basis (rolling 12 -month totals not required) using the most recent version of the EPA's Landfill Gas Emissions Model (LandGEM) or the calculation method from AP -42 2.4. VOC emissions shall be 39% of the total NMOC emissions determined. Annual emission calculations of VOC, NMOC, and HAPs, along with the waste acceptance rate records shall be maintained for Division inspection upon request (Construction Permit 91WE766, as modified under the provisions of Section I, Condition 1.3). 2.2 The VOC emissions from petroleum -contaminated soils, when used as daily cover, shall not exceed the lift in the table above. The peranittee shall calculate emissions from contaminated materials rec4ived by using a mass balance based on the concentration of contaminants and the quantity of materials accepted (Colorado Construction Permit 91WE766) rM u 2.2.1 Tl 9 permittee shall sample incoming contaminated soils semi-annually to determine V_Q!C content for use in calculations. Alternatively, the analysis of soils provided by the'generator may be used. 2.2.2 The amount of petroleum -contaminated soil accepted, and the amount of petroleum - contaminated soil used as daily cover shall be recorded on a monthly basis and used in the emission calculation. 2.3 The waste acceptance rate shall not exceed the limitations stated above (Construction Permit 91WE766, as modified under the provisions of Section I, Condition 1.3). Waste acceptance shall Operating Permit 97OPWE188 First Issued: October 1, 2000 Renewed: July 1, 2006 ATTACHMENT 3 SUPPORTING EMISSION RATE CALCULATIONS • FUGITIVE HAP EMISSIONS CALCULATIONS FRONT RANGE LANDFILL Fugitive Emissions: 40% of the estimated landfill fugitive CH4 generation rate in 2027: Speciated LFG Compounds CAS No. VOC HAP MW (lbllb-mol) Conc.' Annual Fugitive Emissionsb (ppmv) lb/hr lb/yr ton/yr 1,1,1 - Trichloroethane (methyl chloroform) 71-55-6 X 133.41 0.48 0.0326 285.836 0.143 1,1,2,2 - Tetrachloroethane 79-34-5 X X 167.85 1.10 0.0941 824.141 0.412 1,1 - Dichloroethane (ethylidene dichloride) 75-34-3 X X 98.97 2.40 0.1210 1060.235 0.530 1,1 - Dichloroethene (vinylidene chloride) 75-35-4 X X 96.94 0.20 0.0099 86.973 0.043 1,2 - Dichloroethane (ethylene dichloride) 107-06-2 X X 98.96 0.41 0.0205 179.780 0.090 1,2 - Dichloropropane (propylene dichloride) 78-87-5 X X 112.99 0.18 0.0104 90.782 0.045 2-Propanol (isopropyl alcohol) 67-63-0 X 60.11 50.00 1.5314 13415.419 6.708 Acetone 67-64-1 58.08 7.00 0.2072 1814.731 0.907 Acrylonitrile 107-13-1 X X 53.06 6.30 0.1703 1492.091 0.746 Bromodichloromethane 75-27-4 X 163.83 3.10 0.2588 2266.954 1.133 Butane 106-97-8 X 58.12 5.00 0.1481 1297.129 0.649 Benzene 71-43-2 X X 78.11 1.90 0.0756 662.442 0.331 Carbon Disulfide 75-15-0 X X 76.13 0.58 0.0226 198.113 0.099 Carbon Tetrachloride 56-23-5 X X 153.84 0.004 0.0003 2.747 0.001 Carbonyl Sulfide 463-58-1 X X 60.07 0.49 0.0150 131.384 0.066 Chlorobenzene 108-90-7 X X 112.56 0.25 0.0146 127.616 0.064 Chlorodifluoromethane 75-45-6 86.47 1.30 0.0573 501.760 0.251 Chloroethane (ethyl chloride) 75-00-3 X X 64.52 1.30 0.0427 374.391 0.187 Chloroform 67-66-3 X X 119.39 0.03 0.0018 15.987 0.008 Chloromethane (methyl chloride) 74-87-3 X X 50.49 1.20 0.0309 270.442 0.135 Dichlorobenzene 95-50-1 X X 147.0 0.21 0.0157 137.792 0.069 Dichlorodifluoromethane 75-71-8 120.91 16.00 0.9857 8635.147 4.318 Dichlorofluoromethane 75-43-4 X 102.92 2.60 0.1364 1194.430 0.597 Dichloromethane (methylene chloride) 75-09-2 X 84.94 14.00 0.6059 5307.962 2.654 Dimethyl Sulfide (methyl sulfide) 75-18-3 X 62.13 7.80 0.2469 2163.134 1.082 Ethane 74-84-0 30.07 890.00 13.6366 119456.823 59.728 Ethanol 64-17-5 X 46.08 27.00 0.6340 5553.461 2.777 Ethyl Mercaptan (ethanethiol) j a 75-08-1 X 62.13 2.30 0.0728 637.847 0.319 Ethylbenzene ! 100-41-4 X X 106.16 4.60 0.2488 2179.748 1.090 Ethylene dibromide a ii 106-93-4 X X 187.88 0.0010 0.0001 0.839 0.000 Fluorotrichloromethane : r ;j 75-69-4 X 137.38 0.76 0.0532 466.042 0.233 Hexane i' 110-54-3 X X 86.18 6.60 0.2898 2538.855 1.269 Hydrogen Sulfide P. ;7 7783-06-4 34.08 36.00 0.6252 5476.330 2.738 Mercury (total) ,r .i! 7439-97-6 X 200.61 0.0003 0.0000 0.261 0.000 Methyl Ethyl Ketone 'l:1 78-93-3 X 72.11 7.10 0.2609 2285.290 1.143 Methyl Isobutyl Ketone 108-10-1 X X 100.16 1.90 0.0970 849.445 0.425 Methyl Mercaptan 74-93-1 X 48.11 2.50 0.0613 536.862 0.268 Pentane 109-66-0 X 72.15 3.30 0.1213 1062.766 0.531 Perchloroethylene (tetrachloroethylene) 127-18-4 X 165.83 3.70 0.3126 2738.750 1.369 Propane 74-98-6 X 44.09 11.00 0.2471 2164.813 1.082 24,759,438 m3/yr F:IWCIFronl RangeILFGI4PEMM rch 20161 Attachment 3.1 - Revised Speciated VOCs. Weaver Consultants Group 3/30/2016 FUGITIVE HAP EMISSIONS CALCULATIONS FRONT RANGE LANDFILL Speciated LFG Compounds CAS No. VOC HAP MW (lb/lb-mol) Conc.' (ppmv) Annual Fugitive Emissions" lb/hr lb/yr ton/yr t-1,2-Dichloroethene (1,2 dichloroethylene) 156-60-5 X 96.94 2.80 0.1383 1211.570 0.606 Toluene 108-88-3 X X 92.13 39.00 1.8308 16038.111 8.019 Trichloroethylene(tchloroethene) 79-01-6 X X 131.4 2.80 0.1875 1642.256 0.821 Vinyl Chloride 75-01-4 X X 62.5 7.30 0.2325 2036.528 1.018 Xylenes 1330-20-7 X X 106.16 12.00 0.6491 5686.299 2.843 Total HAPs 22.480 The concentrations for LFG compounds were the default LandGEM version 3.02 concentration. b These fugitive emissions were calculated by using the equations # 3 and # 4 from AP -42, Section 2.4 (11/98) and by using the concentration for each compound. The CAS No. 106-46-7 (1,4-Dichlorobenzene) is the CAS No. used to report Dichlorobenzene on the Turn -Around Document, since AP -42 does not "indicate whether this compound was the pars- or ortho- isomer. The pars isomer is a Title Ill -listed HAP." Ii F:IWCIF ont RangeILFGI PENIMarch 20161 Attachment 3.1 - Revised Speciated VOCs. Weaver Consultants Group 3/30/2016 Potential Landfill Fugitive Emission Calculation Front Range Landfill Requirement: Determine the 2027 potential fugitive VOC emissions from the landfill using the 2027 non -methane organic compound (NMOC) generation predicted by the EPA Landfill Gas Emissions Model. The 2027 total VOC emissions shall be 39% of the total NMOC emission that is estimated by the model using projected waste in -place through 2026. Since the landfill has a gas collection and control system (GCCS), the 2027 fugitive VOC emissions are equal to 40% of the 2027 total VOC emissions assuming a conservative 60% of the 2027 total VOC emissions are collected through the GCCS. 2027 Fugitive VOC Calculation: - Conversion Factors 0.907 Mg = 1 ton Estimated 2027 NMOC predicted by the EPA model is: 2027 NMOC = 424.22 Mg/year 2027 NMOC = 467.72 tons/year 2027 Total VOC Emissions 2027 Total VOC Emissions 2027 Fugitive VOC Emissions 2027 Fugitive VOC Emissions = 2027 NMOC tons/year x 39% = 182.41 tons/year = 2027 Total VOC Emissions * 40% = 72.96 tons/year F:\WC\Front Range\LFG\APEN\March 2016\Attachment 3.2 - Potential Fugitive VOC Emissions Weaver Consultants Group Attachment 3.3 - Landgem 3/30/2016 Us EPA Office of Research end Development A T U.S. Environmental Protection Agency Office of Research and Development National Risk Management Research Laboratory (NRMRL) and Clean Air Technology Center (CATC) Research Triangle Park, North Carolina Summary Report Landfill Name or Identifier: Front Range Landfill Date: Wednesday, March 30, 2016 Description/Comments: LandGEM parameters utilized per PS Memo # 12-01 - PCS Calculation Procedures About LandGEM: First -Order Decomposition Rate Equation: 1 �i QCH4 =1± ±kL"110)e—ictil i=1 j=0.1 Where, QCH4 = annual methane generation in tlje;:year of the calculation (m3/year) i = 1 -year time increment = M, = mass of waste accepted in the ie year (Mg) n = (year of the calculation) - (initial year!,Eaf waste acceptance) ti = age of the jei section of waste mass M, accepted in the ith year j = 0.1 -year time increment !; ; (decimal years, e.g., 3.2 years) k = methane generation rate (year -1) • C I,I Ln = potential methane generation capap(ty (m3/Mg) LandGEM is based on a first -order decposition rate equation for quantifying emissions from the decomposition of landfilled waste in municipal solid waste (MSW) landfills. Tie 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 (CM) regulations, and other guidance regarding landfill gas emissions and control technology requirements can be found at http://www.epa.govittnatw01/landfill/landfipg.html. LandGEM is considered a screening tool — 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 CM applicability. Refer to the Web site identified above for future updates. REPORT- 1 Attachment 3.3 - Landgem 3/30/2016 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, Lo NMOC Concentration Methane Content GASES / POLLUTANTS SELECTED Gas / Pollutant #1: Total landfill gas Gas / Pollutant #2: Methane Gas / Pollutant #3: Gas / Pollutant #4: NMOC WASTE ACCEPTANCE RATES 1996 2026 2026 Yes 35,768,342 megagrams 0.020 year -1 100 m3/Mg 956 ppmv as hexane 50 % by volume Year Waste Accepted Waste -In -Place (Mg/year) (short tons/year) (Mg) (short tons) 1996 58,656 64,522 0 0 1997 274,010 301,411 58,656 64,522 1998 291,186 320,305 332,666 365,933 1999 114,486 125,935 623,852 686,237 2000 179,357 197,293 738,338 812,172 2001 150,959 166,055 917,695 1,009,465 2002 149,611 164,572 1,068,654 1,175,519 2003 152,976 168,274 1,218,265 1,340,092 2004 166,255 182,881 1,371,241 1,508,365 2005 187,560 206,316 1,537,496 1,691,246 2006 187,749 206,524 1,725,056 1,897,562 2007 196,790 216,469 1,912,805 2,104,086 2008 214,632 236,095 2,109,595 2,320,555 2009 145,124 159,636 2,324,227 2,556,650 2010 0 0 2,469,351 2,716,286 2011 191,604 210,765 2,469,351 2,716,286 2012 730,797 803,877 2,660,955 2,927,051 2013 858,562 944,418 3,391,752 3,730,928 2014 943,408 1,037,749 4,250,314 4,675,345 2015 1,013,108 1,114,419 5,193,722 5,713,094 2016 2,721,000 , 2,993,100 6,206,830 6,827,513 2017 2,721,000 2,993,100 8,927,830 9,820,613 2018 2,721,000 2,993,100 11,648,830 12,813,713 2019 2,721,000 4 i 2,993,100 14,369,830 15,806,813 2020 2,721,000 x;t 2,993,100 17,090,830 18,799,913 2021 2,721,000 rk iI 2,993,100 19,811,830 21,793,013 2022 2,721,000 „;; 2,993,100 22,532,830 24,786,113 2023 2,721,000 •ii 1 2,993,100 25,253,830 27,779,213 2024 2,721,000 C;y 2,993,100 27,974,830 30,772,313 2025 2,721,000 ;r 2,993,100 30,695,830 33,765,413 2026 2,351,513 r i:1 2,586,664 33,416,830 36,758,513 2027 0 0 35,768,342 39,345,177 2028 0 0 35,768,342 39,345,177 2029 0 0 35,768,342 39,345,177 2030 0 0 35,768,342 39,345,177 REPORT -2 Attachment 3.3 - Landgem 3/30/2016 Results Year Total landfill gas Methane (Mg/year) (m 3/year) (av ft"3/min) (Mg/year) (m 3/year) (av ft^3/min) 1996 0 0 0 0 0 0 1997 2.904E+02 2.325E+05 1.562E+01 7.756E+01 1.163E+05 7.812E+00 1998 1.641E+03 1.314E+06 8.830E+01 4.384E+02 6.571E+05 4.415E+01 1999 3.050E+03 2.442E+06 1.641E+02 8.147E+02 1.221E+06 8.205E+01 2000 3.557E+03 2.848E+06 1.914E+02 9.500E+02 1.424E+06 9.568E+01 2001 4.374E+03 3.503E+06 2.353E+02 1.168E+03 1.751E+06 1.177E+02 2002 5.035E+03 4.032E+06 2.709E+02 1.345E+03 2.016E+06 1.354E+02 2003 5.676E+03 4.545E+06 3.054E+02 1.516E+03 2.272E+06 1.527E+02 2004 6.321E+03 5.061E+06 3.401E+02 1.688E+03 2.531E+06 1.700E+02 2005 7.019E+03 5.620E+06 3.776E+02 1.875E+03 2.810E+06 1.888E+02 2006 7.808E+03 6.252E+06 4.201E+02 2.086E+03 3.126E+06 2.101E+02 2007 8.583E+03 6.873E+06 4.618E+02 2.293E+03 3.436E+06 2.309E+02 2008 9.387E+03 7.517E+06 5.051E+02 2.507E+03 3.758E+06 2.525E+02 2009 1.026E+04 8.219E+06 5.522E+02 2.742E+03 4.109E+06 2.761E+02 2010 1.078E+04 8.632E+06 5.799E+02 2.879E+03 4.316E+06 2.900E+02 2011 1.057E+04 8.461E+06 5.685E+02 2.822E+03 4.230E+06 2.842E+02 2012 1.131E+04 9.053E+06 6.082E+02 3.020E+03 4.526E+06 3.041E+02 2013 1.470E+04 1.177E+07 7.909E+02 3.926E+03 5.885E+06 3.954E+02 2014 1.866E+04 1.494E+07 1.004E+03 4.984E+03 7.470E+06 5.019E+02 2015 2.296E+04 1.838E+07 1.235E+03 6.133E+03 9.192E+06 6.176E+02 2016 2.752E+04 2.204E+07 1.481E+03 7.351E+03 1.102E+07 7.403E+02 2017 4.045E+04 3.239E+07 2.176E+03 1.080E+04 1.619E+07 1.088E+03 2018 5.312E+04 4.253E+07 2.858E+03 1.419E+04 2.127E+07 1.429E+03 2019 6.553E+04 5.248E+07 3.526E+03 1.751E+04 2.624E+07 1.763E+03 2020 7.771E+04 6.222E+07 4.181E+03 2.076E+04 3.111E+07 2.090E+03 2021 8.964E+04 7.178E+07 4.823E+03 2.394E+04 3.589E+07 2.411E+03 2022 1.013E+05 8.114E+07 5.452E+03 2.707E+04 4.057E+07 2.726E+03 2023 1.128E+05 9.032E+07 6.069E+03 3.013E+04 4.516E+07 3.034E+03 2024 1.240E+05 9.932E+07 6.673E+03 3.313E+04 4.966E+07 3.337E+03 2025 1.351E+05 1.081E+08 7.266E+03 3.607E+04 5.407E+07 3.633E+03 2026 1.458E+05 1.168E+08 7.847E+03 3.896E+04 5.839E+07 3.923E+03 2027 1.546E+05 1.238E+08 8.318E+03 4.130E+04 6.190E+07 4.159E+03 2028 1.515E+05 1.213E+08 8.153E+03 4.048E+04 6.067E+07 4.077E+03 2029 1.485E+05 1.189E+08 7.992E+03 3.968E+04 5.947E+07 3.996E+03 2030 1.456E+05 1.166E+08 7.834E+03 3.889E+04 5.829E+07 3.917E+03 REPORT -3 Attachment 3.3 - Landgem Results (Continued) 3/30/2016 Year NMOC (Mg/year) (m3 /year) (av ft"3/min) 1996 0 0 0 1997 7.968E-01 2.223E+02 1.494E-02 1998 4.503E+00 1.256E+03 8.441E-02 1999 8.370E+00 2.335E+03 1.569E-01 2000 9.759E+00 2.723E+03 1.829E-01 2001 1.200E+01 3.348E+03 2.250E-01 2002 1.382E+01 3.854E+03 2.590E-01 2003 1.557E+01 4.345E+03 2.919E-01 2004 1.734E+01 4.839E+03 3.251E-01 2005 1.926E+01 5.373E+03 3.610E-01 2006 2.143E+01 5.977E+03 4.016E-01 2007 2.355E+01 6.571E+03 4.415E-01 2008 2.576E+01 7.186E+03 4.828E-01 2009 2.816E+01 7.857E+03 5.279E-01 2010 2.958E+01 8.252E+03 5.544E-01 2011 2.899E+01 8.088E+03 5.435E-01 2012 3.102E+01 8.654E+03 5.815E-01 2013 4.033E+01 1.125E+04 7.561 E-01 2014 5.120E+01 1.428E+04 9.597E-01 2015 6.300E+01 1.758E+04 1.181E+00 2016 7.552E+01 2.107E+04 1.416E+00 2017 1.110E+02 3.096E+04 2.080E+00 2018 1.457E+02 4.066E+04 2.732E+00 2019 1.798E+02 5.017E+04 3.371E+00 2020 2.132E+02 5.949E+04 3.997E+00 2021 2.460E+02 6.862E+04 4.611E+00 2022 2.781E+02 7.757E+04 5.212E+00 2023 3.095E+02 8.635E+04 5.802E+00 2024 3.404E+02 9.495E+04 6.380E+00 2025 3.706E+02 1.034E+05 6.946E+00 2026 4.002E+02 1.116E+05 7.502E+00 2027 4.242E+02 1.184E+05 7.952E+00 2028 4.158E+02 1.160E+05 7.794E+00 2029 4.076E+02 1.137E+05 7.640E+00 2030 3.995E+02 1.115E+05 7.489E+00 REPORT — 4 ATTACHMENT 4 AIR POLLUTANT EMISSION NOTICE 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 whioh 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 11.6.4. 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. 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 FUGITIVE HAP EMISSIONS CALCULATIONS FRONT RANGE LANDFILL Fugitive Emissions: 40% of estimated landfill fugitive CH4 generation rate in 2016: 4,407,410 m3/yr Speciated LFG Compounds CAS No. VOC HAP MW (lb/lb-mop Conc.' (ppmv) Annual Fugitive Emissions" lb/hr lb/yr ton/yr 1,1,1 - Trichloroethane (methyl chloroform) 71-55-6 X 133.41 0.48 0.0058 50.881 0.025 1,1,2,2 - Tetrachloroethane 79-34-5 X X 167.85 1.10 0.0167 146.705 0.073 1,1 - Dichloroethane (ethylidene dichloride) 75-34-3 X X 98.97 2.40 0.0215 188.732 0.094 1,1 - Dichloroethene (vinylidene chloride) 75-35-4 X X 96.94 0.20 0.0018 15.482 0.008 1,2 - Dichloroethane (ethylene dichloride) 107-06-2 X X 98.96 0.41 0.0037 32.003 0.016 1,2 - Dichloropropane (propylene dichloride) 78-87-5 X X 112.99 0.18 0.0018 16.160 0.008 2-Propanol (isopropyl alcohol) 67-63-0 X 60.11 50.00 0.2726 2388.070 1.194 Acetone 67-64-1 58.08 7.00 0.0369 323.039 0.162 Acrylonitrile 107-13-1 X X 53.06 6.30 0.0303 265.606 0.133 Bromodichloromethane 75-27-4 X 163.83 3.10 0.0461 403.539 0.202 Butane 106-97-8 X 58.12 5.00 0.0264 230.901 0.115 Benzene 71-43-2 X X 78.11 1.90 0.0135 117.921 0.059 Carbon Disulfide 75-15-0 X X 76.13 0.58 0.0040 35.266 0.018 Carbon Tetrachloride 56-23-5 X X 153.84 0.004 0.0001 0.489 0.000 Carbonyl Sulfide 463-58-1 X X 60.07 0.49 0.0027 23.388 0.012 Chlorobenzene 108-90-7 X X 112.56 0.25 0.0026 22.717 0.011 Chlorodifluoromethane 75-45-6 86.47 1.30 0.0102 89.318 0.045 Chloroethane (ethyl chloride) 75-00-3 X X 64.52 1.30 0.0076 66.645 0.033 Chloroform 67-66-3 X X 119.39 0.03 0.0003 2.846 0.001 Chloromethane (methyl chloride) 74-87-3 X X 50.49 120 0.0055 48.141 0.024 Dichlorobenzene0 95-50-1 X X 147.0 0.21 0.0028 24.528 0.012 Dichlorodifluoromethane 75-71-8 120.91 16.00 0.1755 1537.137 0.769 Dichlorofluoromethane 75-43-4 X 102.92 2.60 0.0243 212.620 0.106 Dichloromethane (methylene chloride) 75-09-2 X 84.94 14.00 0.1079 944.867 0.472 Dimethyl Sulfide (methyl sulfide) 75-18-3 X 62.13 7.80 0.0440 385.058 0.193 Ethane 74-84-0 30.07 890.00 2.4274 21264.426 10.632 Ethanol 64-17-5 X 46.08 27.00 0.1129 988.568 0.494 Ethyl Mercaptan (ethanethiol) a 75-08-1 X 62.13 2.30 0.0130 113.543 0.057 Ethylbenzene 100-41-4 X X 106.16 4.60 0.0443 388.015 0.194 Ethylene dibromide ii it 1 106-93-4 X X 187.88 0.0010 0.0000 0.149 0.000 Fluorotrichloromethane .I:;it cI 75-69-4 X 137.38 0.76 0.0095 82.960 0.041 Hexane 110-54-3 X X 86.18 6.60 0.0516 451.940 0.226 Hydrogen Sulfide - 7783-06-4 34.08 36.00 0.1113 974.838 0.487 Mercury (total) 7 Methyl Ethyl Ketone � i 7439-97-6 78-93-3 X X 200.61 72.11 0.0003 7.10 0.0000 0.0464 0.047 406.803 0.000 0.203 Methyl Isobutyl Ketone 108-10-1 X X 100.16 1.90 0.0173 151.209 0.076 Methyl Mercaptan 74-93-1 X 48.11 2.50 0.0109 95.566 0.048 Pentane 109-66-0 X 72.15 3.30 0.0216 189.182 0.095 Perchloroethylene (tetrachloroethylene) 127-18-4 X 165.83 3.70 0.0557 487.523 0.244 Propane 74-98-6 X 44.09 11.00 0.0440 385.357 0.193 F: IWC1Front RangetLFGLAPEMMarch 20161 Attachment 4.3 - Remised Speciated VOCs Weaver Consultants Group 3/30/2016 FUGITIVE HAP EMISSIONS CALCULATIONS FRONT RANGE LANDFILL Speciated LFG Compounds CAS No. VOC HAP MW (lb/lb-moll Conc." (ppanv) Annual Fugitive Emissionsb lb/hr lb/yr ton/yr t-1,2-Dichloroethene (1,2 dichloroethylene) 156-60-5 X 96.94 2.80 0.0246 215.671 0.108 Toluene 108-88-3 X X 92.13 39.00 0.3259 2854.933 1.427 Trichloroethylene (trichloroethene) 79-01-6 X X 131.4 2.80 0.0334 292.337 0.146 Vinyl Chloride 75-01-4 X X 62.5 730 0.0414 362.521 0.181 Xylenes 1330-20-7 X X 106.16 12.00 0.1155 1012.214 0.506 Total HAPs 4.002 ° The concentrations for LFG compounds were the default LandGEM version 3.02 concentration. b These fugitive emissions were calculated by using the equations # 3 and # 4 from AP -42, Section 2.4 (11/98) and by using the concentration for each compound. The CAS No. 106-46-7 (1,4-Dichlorobenzene) is the CAS No. used to report Dichiorobenzene on the Turn -Around Document, since AP -42 does not "indicate whether this compound was the pars- or ortho- isomer. The pars isomer is a Title III -listed HAP." F.IWCIFront RangeILFGIAFEMMarch 20161 Attachment 4.3 - Revised Speciated VOCs 3/30/2016 Weaver Consultants Group Attachment 4.4 - Landgem 3/30/2016 ORD US EPA Office et Reseuch and Derelopmeat A Summary Report Landfill Gas Emissions Model Version 3.02 U.S. Environmental Protection Agency Office of Research and Development National Risk Management Research Laboratory (NRl4RL) and Clean Air Technology Center (CATC) Research Triangle Park, North Carolina Landfill Name or Identifier: Front Range Landfill Date: Wednesday, March 30, 2016 Description/Comments: LandGEM parameters utilized per PS Memo # 12-01 - PCS Calculation Procedures About LandGEM: n 1 First Order Decomposition Rate Equation: Qe,1I4 = E o )e-kti i Where, i=1 j=0.1 1 Q QCH4 = annual methane generation in the year of the calculation (m3/year) i = 1 -year time increment ° ` M1= mass of waste accepted in the ith year (Mg) n = (year of the calculation) - (initial yearbf waste acceptance) ti = age of the ja' section of waste mass M, accepted in the iei year j = 0.1 -year time increment ;;t (decimal years, e.g., 3.2 years) k = methane generation rate (year -11 ,I, !{ L„ = potential methane generation capa�gtty (m3 /Mg) LandGEM is based on a first -order dec4tOposition rate equation for quantifying emissions from the decomposition of landfilled waste in municipal solid waste (MSW) landfills. rf, a 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.govittnatw01/landfill/landflpg.html. LandGEM is considered a screening tool — 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 Attachment 4.4 - Landgem 3/30/2016 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, Lo NMOC Concentration Methane Content GASES / POLLUTANTS SELECTED Gas / Pollutant #1: Total landfill gas Gas / Pollutant #2: Methane Gas / Pollutant #3: Gas / Pollutant #4: NMOC ACCEPTANCE RATES 1996 2045 2045 Yes 35,768,342 megagrams 0.020 year'' 100 m3/Mg 956 ppmv as hexane 50 % by volume Year Waste Accepted Waste -In -Place (Mg/year) (short tons/year) (Mg) (short tons) 1996 58,656 64,522 0 0 1997 274,010 301,411 58,656 64,522 1998 291,186 320,305 332,666 365,933 1999 114,486 125,935 623,852 686,237 2000 179,357 197,293 738,338 812,172 2001 150,959 166,055 917,695 1,009,465 2002 149,611 164,572 1,068,654 1,175,519 2003 152,976 168,274 1,218,265 1,340,092 2004 166,255 182,881 1,371,241 1,508,365 2005 187,560 206,316 1,537,496 1,691,246 2006 187,749 206,524 1,725,056 1,897,562 2007 196,790 216,469 1,912,805 2,104,086 2008 214,632 236,095 2,109,595 2,320,555 2009 145,124 159,636 2,324,227 2,556,650 2010 0 0 2,469,351 2,716,286 2011 191,604 210,765 2,469,351 2,716,286 2012 730,797 803,877 2,660,955 2,927,051 2013 858,562 944,418 3,391,752 3,730,928 2014 943,408 1,037,749 4,250,314 4,675,345 2015 1,013,108 1,114,419 5,193,722 5,713,094 REPORT— 2 Attachment 4.4 - Landgem 3/30/2016 Results Year Total landfill gas Methane (Mg/year) (m 3/year) (av ft^3/min) (Mg/year) (m 3/year) (av ft^3/min) 1996 0 0 0 0 0 0 1997 2.904E+02 2.325E+05 1.562E+01 7.756E+01 1.163E+05 7.812E+00 1998 1.641E+03 1.314E+06 8.830E+01 4.384E+02 6.571E+05 4.415E+01 1999 3.050E+03 2.442E+06 1.641E+02 8.147E+02 1.221E+06 8.205E+01 2000 3.557E+03 2.848E+06 1.914E+02 9.500E+02 1.424E+06 9.568E+01 2001 4.374E+03 3.503E+06 2.353E+02 1.168E+03 1.751E+06 1.177E+02 2002 5.035E+03 4.032E+06 2.709E+02 1.345E+03 2.016E+06 1.354E+02 2003 5.676E+03 4.545E+06 3.054E+02 1.516E+03 2.272E+06 1.527E+02 2004 6.321E+03 5.061E+06 3.401E+02 1.688E+03 2.531E+06 1.700E+02 2005 7.019E+03 5.620E+06 3.776E+02 1.875E+03 2.810E+06 1.888E+02 2006 7.808E+03 6.252E+06 4.201E+02 2.086E+03 3.126E+06 2.101E+02 2007 8.583E+03 6.873E+06 4.618E+02 2.293E+03 3.436E+06 2.309E+02 2008 9.387E+03 7.517E+06 5.051E+02 2.507E+03 3.758E+06 2.525E+02 2009 1.026E+04 8.219E+06 5.522E+02 2.742E+03 4.109E+06 2.761E+02 2010 1.078E+04 8.632E+06 5.799E+02 2.879E+03 4.316E+06 2.900E+02 2011 1.057E+04 8.461E+06 5.685E+02 2.822E+03 4.230E+06 2.842E+02 2012 1.131E+04 9.053E+06 6.082E+02 3.020E+03 4.526E+06 3.041E+02 2013 1.470E+04 1.177E+07 7.909E+02 3.926E+03 5.885E+06 3.954E+02 2014 1.866E+04 1.494E+07 1.004E+03 4.984E+03 7.470E+06 5.019E+02 2015 2.296E+04 1.838E+07. 1.235E+03 6.133E+03 9.192E+06 6.176E+02 2016 2.752E+04 2.204E+07 1.481E+03 7.351E+03 1.102E+07 7.403E+02 '4 I. 4' REPORT - 3 Attachment 4.4 - Landgem 3/30/2016 Results (Continued) Year NMOC (Mg/year) (m3 /year) (av ft"3/min) 1996 0 0 0 1997 7.968E-01 2.223E+02 1.494E-02 1998 4.503E+00 1.256E+03 8.441E-02 1999 8.370E+00 2.335E+03 1.569E-01 2000 9.759E+00 2.723E+03 1.829E-01 2001 1.200E+01 3.348E+03 2.250E-01 2002 1.382E+01 3.854E+03 2.590E-01 2003 1.557E+01 4.345E+03 2.919E-01 2004 1.734E+01 4.839E+03 3.251E-01 2005 1.926E+01 5.373E+03 3.610E-01 2006 2.143E+01 5.977E+03 4.016E-01 2007 2.355E+01 6.571E+03 4.415E-01 2008 2.576E+01 7.186E+03 4.828E-01 2009 2.816E+01 7.857E+03 5.279E-01 2010 2.958E+01 8.252E+03 5.544E-01 2011 2.899E+01 8.088E+03 5.435E-01 2012 3.102E+01 8.654E+03 5.815E-01 2013 4.033E+01 1.125E+04 7.561E-01 2014 5.120E+01 1.428E+04 9.597E-01 2015 6.300E+01 1.758E+04 1.181E+00 2016 7.552E+01 2.107E+04 1.416E+00 Z. REPORT- 4 Colorado Department of Public Health and Environment Air Pollution Control Division MUNICIPAL SOLID WASTE LANDFILLS Air Pollutant Emission Notice (APEN) - and- Application for Construction Permit All sections of this APEN and application must be completed prior to submittal to the Division for both new and existing facilities. An application with missing information may be determined incomplete and may be returned to you or result in longer engineer processing times. Requested Action: ❑ New Landfill, Apply for Construction Permit 0 Change in Design Capacity O Transfer of Ownership' Change Company Name O No Change in Permit, APEN Update Only O Change in Waste Acceptance ® Request Other Permit Modification 'Note: For transfer of ownership or company name change, you must submit proof of ownership transfer (e.g., Transfer of Ownership Form signed by the previous owner or a copy of a Bill of Sale with this form). PERMIT NUMBER: 97OPWE188 SECTION 01- ADMINISTRATIVE INFORMATION Landfill Name: Front Range Landfill Landfill Address: Billing Address: Person to Contact: Contact Email Address: Landfill Owner: Address of Owner: Landfill Operator (if different) Landfill Operator Address: FACILITY AIRS ID: 1830 Weld County Road 5 Erie, CO P.O. Box 320 Erie, CO Dan Gudgel DanG@WasteConnections.com Front Range Landfill, Inc. 1830 Weld County Road 5 Erie, CO Same Same l� �9 SECTION 02 - GENERAL..INFORMATION 123 0079 009 County: Weld Zip Code: 80516 Zip Code: 80516 Phone Number: (303) 673-9431 Fax Number: (303) 641-2146 Phone Number: (303) 673-9431 Zip Code: 80516 Phone Number: Zip Code: Landfill: q,? ;, ,,: Approximate Date Comments Commenced constructidion (Existing): 1996 ■ Will commence construction on (New): • Was closed on: ■ Projected closure date: 346145 MSW Landfill APEN 01-2013 1 Colorado Department of Public Health and Environment Air Pollution Control Division MUNICIPAL SOLID WASTE LANDFILLS SECTION 03 -DESIGN CAPACITY INFORMATION Select the appropriate scenario below: ❑ New or Previously unreported landfill. [ ] Complete the "Design Capacity Report Form" and submit it with this APEN. [ ] Date the Certificate of Designation was approved: ❑ Change to a previously reported design capacity. [] Complete the "Design Capacity Report Form" and submit it with this APEN. [ ] Date the Certificate of Designation was approved: ® No change to design capacity. [X ] Date the most recent Design Capacity Report Form was submitted: June 30, 2010 List the Landfill Design Capacity in both volume and masse: m3 If you are reporting a cchange in design capacity, list NA m 3 the new capacity here2: 2Calculate m 3 by multiplying yd 3 by 0.7646. Calculate Mg by multiplying tons by 0.907. 35,768,342 Megagrams (Mg) NA Megagrams (Mg) Landfill is subject to (check all that apply): ❑ NSPS Subpart Cc ® NSPS WWW ® Title V ® NESHAP Subpart AAAA Other SECTION 04 - WASTE ACCEPTANCE INFORMATION This landfill measures solid waste acceptance in: ® Tons ❑ Cubic yards (Specify Gate Volume or In Place Volume): t ';c ❑ Other (please explain): !!: 6,1 Specify the types of materialsLtj at are or would be accepted at the landfill. For each type, list the actual waste acceptance rate and the requested permit limit. (e.g., fly ash, petroleum contaminated soils, non -degradable material...) Type of Material's Accepted (List Actual Annual Waste Acceptance Rate (include units) Reporting Year: 2015 Requested Annual Permit Acceptance Limit (include units) Solid Waste* 't '1 1,440,595 tons 3,000,000 tons *Includes all waste streams the landfill accepts including but not limited to municipal solid waste, commercial waste, industrial waste, petroleum contaminated soil, asbestos and ect. MSW Landfill APEN 01-2013 2 Colorado Department of Public Health and Environment Air Pollution Control Division MUNICIPAL SOLID WASTE LANDFILLS Beginning with the year the landfill opened, list the total waste acceptance amount for each year or submit the LandGEM waste acceptance data with this APEN. Specify units. If any acceptance rates are estimated, attach documentation that demonstrates how acceptance rates were calculated. Year _ I Waste Accepted Year Waste Accepted See attached LandGEM Year Waste Accepted LandGEM data has been submitted with this APEN. Note: The APCD is currently using AP -42 Section 2.4 to estimate landfill gas emissions. The Landfill Gas Emissions Model (LandGEM) is based on this AP -42 section and can be used to provide this information. . SECTION 05 - OTHER LANDFILL ACTIVITIES Check appropriate box(es) below to indicate other activities and/or equipment at the landfill that may require submission of a separate APEN form. Composting (describe activity): • Engine(s)/Generator(s) (specify type): • Leachate (on -site use): II Washer (describe activity): Insignificant activity 0Parts Sand & Gravel Operations (describe activity): ■ Solidification Basin (describe activity): U Other (specify activity/equipment): ■ SECTION 06 - FLARE INFORMATION (if not applicable mark N/A) Type of Equipment3 Equ went Manufacturer Make Model Number Serial No. Utility Flare N/A P ;� Parnell Biogas, Inc. N/A PNL 101 12-115 iii !b d. L!: i! Submit additional sheets if necessary. Fuel Type Design Input Rate (106 Btu/hr) Actual Fuel Usage Level (for data year) Fuel Heating Value (indicate units) Landfill Gas 60 MM BTU/hr 171.8 MMcf for 2015 1,051.2 MMcf (Permit No. 97OPWEI88) 291.52 BTU/scf (October 2013 Flare Performance Test)- MSW Landfill APEN 01-2013 3 Colorado Department of Public Health and Environment Air Pollution Control Division MUNICIPAL SOLID WASTE LANDFILLS SECTION 06- continued: AU I chi& Flare Stack ID No. Base Elevation (feet) Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) Utility Flare 5,160 33' NA 2,000 42.4 (October 2013 Flare Performance Test) NA Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) WGS84 13 525,200 E 4,229,960 N Direction of outlet (check one): ®Vertical ['Vertical with obstruction rain cap ['Horizontal ❑Down ['Other Exhaust Opening Shape & ize (check one): ® Circular: Inner Diameter (aches) = _10.4 ❑Other: Length (inches) _,' Width (inches) = _ MSW Landfill APEN 01-2013 4 Colorado Department of Public Health and Environment Air Pollution Control Division MUNICIPAL SOLID WASTE LANDFILLS SECTION 07 - EMISSIONS INVENTORY INFORMATION Note: applicable. • Attach a copy of LandGEM with this APEN form. Sources may have approved site -specific values based on performance testing; attach this information with the APEN form, if Check this box if you would like the Division to calculate your emissions and leave emissions inventory below blank. Reporting Year (e.g., 2010): N/A — Permit Limits Pollutant Type of Control Equipment Overall Collection Efficiency Control Efficiency EF (Include Units) EF Source Actual Calendar Year Emissions4 Requested Emissions5 (Permit Limits) Uncontrolled (tpy) Controlled (tpy) Uncontrolled (tpy) Controlled (tpy) PM -10 N/A N/A N/A 17 lbs/mmscf methane Permit No. 97OPWE188 N/A N/A N/A N/A PM -2.5 N/A N/A N/A N/A N/A N/A N/A N/A N/A V0C Utility Flare N/A 98% NA AP -42 N/A N/A 73.0 (Fugitive) N/A SO26 N/A N/A N/A N/A AP -42 N/A N/A N/A N/A NOx6 Utility Flare N/A N/A 68 lbs/mmscf methane Permit No. 97OPWE188 N/A N/A N/A N/A CO6 Utility Flare N/A N/A 370 lbs/mmscf methane Permit No. 970PWE188 N/A N/A N/A N/A 4 If emissions information is left blank, the APCD will calculate emissions based on information supplied in the APEN, LandGEM or other site -specific information provided with the APEN form. EF = Emission Factor (uncontrolled basis), if applicable. 5Permit limits for flare(s) will be based on the year with maximum emissions, even if after closure. 6Emissions Inventory information above includes emissions from combustion sources (e.g., flares). 4,4171/4?/ ?0,6 MSW Landfill APEN 01-2013 5 Colorado Department of Public Health and Environment Air Pollution Control Division MUNICIPAL SOLID WASTE LANDFILLS 0311E SECTION 08 - FUGITIVE DUST CONTROL MEASURES (Report fugitive emissions and controls at the landfill under normal operating conditions during the reporting year). 1. ONSITE HAULING, AND LOADING/UNLOADING Vehicle Type No. of Vehicles Time Period (# vehicles per month) Loaded Vehicle Weight (tons) Length of Haul Road One Way (feet) All Vehicles est. 130,000 est. 10,833 est. 25 (average) est. 2,500 List maximum posted speed limit on haul roads (miles/hour): 25 CONTROLS: (Check all that apply) .1 Watering ,1 Graveled surfaces ■ Paved surfaces ■ Chemical stabilizer Other (Specify): Speed limit of 25 mph 2. SOIL HANDLING/REMOVAL Maximum: 1,500,000 tons per year CONTROLS: (Check all that apply) I Moist materials // Water I ■ I Others (specify) 3. DISTURBED AREA Total Area of Site (Acres): 660 Total Disturbed Area of Site (Acres): App. 164.9 CONTROLS: L Watering 0 Compaction ►1 Revegetation ■ Other (Specify): SECTION 09 - APPLICANT CERTIFICATION Signature of Legally Authorized„Person (not a vendor or consultant) Date Dan Gudgel Name (please print) r.! .r r. District Manager Title Check the appropriate box if you want: ❑ Copy of the Preliminary Analysis conducted by the Division ❑ To review a draft of the permit prior to issuance (Checking any of these boxes may result in an increased fee and/or processing time) MSW Landfill APEN 01-2013 6 --- Pi l'•,.Ji t.l Er .! s :. i -•I J'. t-.�' (At-'i-.y.) C_.J. P_pplir_ation. for Crtstiuc ion Pcirmit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for municipal solid waste landfills only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, i&A LA L( 2 -S" new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. pe & Permit Number: 97OPWE188 AIRS ID Number: 123 /0079 /009 &0& [Leave blank unless APCO has already assigned a perrni( k and AIRS IDj Section 1 - Administrative Information Company Name': Site Name: Site Location: Front Range Landfill, Inc. Front Range Landfill Site Location 1830 Weld County Road 5 county: Weld Erie, CO 80516 Malting Address: P O. Box 320 (Include Zip Code) Erie, CO 80516 E -Mail Address: Randy.Tourville@WasteConnections.com NAICS or SIC Code: 4953 Permit Contact: Randy Tourville Phone Number: (303) 828-9400 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 375554 Form /..1)C1.1.731 I/uricipai ulid `nit,,L,e Lartdllll /'pEt''! - lie/1`x10(1 12/2016 Permit Number: 97OPWE188 & 11WE1680 AIRS ID Number: 123 /0079 /009 & 013 [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 2- Requested Action O NEW permit OR newly -reported emission source -OR - El MODIFICATION to existing permit (check each box below that applies) 0 Change permit limit ❑ Change company name O Change design capacity 0 Change waste accepted ❑ Transfer of ownership' O Other (describe below) - OR - El APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info a Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information For new landfills, on what date will construction commence? O Complete the "Design Capacity Report Form" and attach it to this APEN. For existing landfills, when did construction commence? 1 996 Change a previously reported design capacity 0 Complete the "Design Capacity Report Form" and attach it to this APEN. For closed landfills, on what date did the landfill close? Form APCD-231 - Municipal Solid Waste Landfill APEN - Revision 12/2016 2 Permit Number: 97OPWE188 & 11WE1680 AIRS iD Number: 123 /0079 /009 & 013 (Leave 'blank unless irCli has already assigned a permit Ti and AIRS It' Section 4 - Landfill Activities Section 4A - Design Capacity information List the current landfill design capacity in volume and mass; m3 and 35, 768, 342 Check here if there is no change to design capacity Mg What is the date that the current Certificate of Designation was approved? 4 Calculate m3 by multiplying yd3 by 0.7646. Calculate Mg by multiplying tons by 0,907. Section 4B - Waste Acceptance Information From what year is the actual annual amount? 2017 June 30, 2010 Description of Materials Accepted5 Actual Annual Waste Acceptance (Specify Units) Requested Annual Permit Acceptance l.imit6 (Specify Units) Solid Waste* 1,951,947 tons 2,230,000 (tons) (Permit No, 970PWE188) *Solid Waste includes PCS 5 Petroleum Contaminated Soil (PCS) acceptance rates should be included in this section, if applicable. 6 Requested values will become permit limitations. Requested limit(s) should consider future process growth. If a control device is not specified, landfill gas emissions will be permitted to accommodate the maximum predicted landfill gas generation. Permit limits for flares will be based on the year with maximum emissions, even after landfill closure. Form APCD'231 - Municipal Solid Waste Landfill APl=N - Revision 12/2016 3 I `Grcai ne Permit Number: 97OPWE188 & 11WE1680 AIRS ID Number: 123 / 0079 / 009 & 013 [Leave blank unless ess APCD has already assigned a permit .and AIRS ID) Section 4C - Waste Acceptance Records Beginning with the year the landfill opened, list the total waste acceptance amount for each year or submit LandGEM waste acceptance data with this APEN. The APCD is currently using AP -42, Section 2.4 to estimate landfill gas emissions. The Landfill Gas Emissions Model (LandGEM) is based on this AP -42 section and can be used to provide this information. If any acceptance rates are estimated, attach documentation that demonstrates how these rates were calculated. Has LandGEM data been submitted with this APEN? lZ Yes 0 No Year Waste Accepted (Specify Units) See LandGem Section 4D - Other Landfill Activities Check the appropriate boxes below to indicate any other activities or equipment at the landfill that may require submission of a separate APEN form. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. Activity Description O Composting Engines or Generators ■ El Parts Washer ❑ Sand ft Gravel Operations ■ Screening Operations [] Solidification Basin El Other Section S - Site Information Geographical Coordinates (Latitude/Longitude orLI M) 4,229,960 N / 525,200 E Form APCD-231 - Municipal. Solid Waste Landfill APEN - Revision 12/2414 A7 7 Permit Number: 97OPWE188 & 11WE1680 AIRS ID Number: 123 /0079 /009 & [Leave blank unless APCD has already assigned a permit. (1 and AIRS ID] Section 6 Flare information El Check this box if a flare is not located at this site, and skip to Section 7. 7 If necessary, attach additional sheets to this APEN. Section 6A - General Flare Information' Operator Stack ID No, Manufacturer Model Number Serial Number Flare Parnell Biogas, Inc. PNL 101 12-115 Section 6B - Flare Stack Information Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (.F) Flow Rate (ACFM) (ACFM) Velocity (ft Flare 33 N/A 2,000 12,4 ( Od 2013 bra Psdomarks Test) indicate the direction of the stack outlet; (check one) 0 Upward D Upward with obstructing raincap O Other (describe): Indicate the stack opening and size: (check one) ID Circular Interior stack diameter (inches); El Square/rectangle Interior stack width (inches): Interior stack depth (inches): ( Other (describe): 10.4 G.okORI co Form APCO 23'I - Municipal Solid Waste Landfill AKIN - Revision 12/2016 5 I Permit Number: 97OPWE188 & 11 WE1680 AIRS ID Number: 123 /0079 /009 & 0i3 [Leave blank unless APCD has already assigned a permit II and AIRS IDi Section 6C - Flare Use Information Operator Stack ID No. Design Input Rate (MMSCF/hr) Actual Annual Fuel Use (MMSCF/yr) Requested Annual Permit Limitb (MMSCFtyr) Flare 0.12 300.8 1,051 From what year is the actual annual fuel use data? 2017 Indicate the type of fuel used: ❑✓ Landfill Gas ❑ Other (describe): Heating value: 506 BTU/SCF Heating value (give units): 6 Requested values will become permit limitations, Requested limits) should consider future process growth. If a control device is not specified, landfill gas emissions will be permitted to accommodate the maximum predicted landfill gas generation. Permit limits for flares will be based on the year with maximum emissions, even after landfill closure. Section 7 - Criteria Pollutant Emissions information Attach a complete copy of the LandGEM `Results' tab with this APEN form. Sources may have approved site - specific values based on performance testing. Attach this information with the APEN form, if applicable. Are any emission control practices or equipment used to reduce emissions? D Yes No t AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Collection Efficiency Overall Control Efficiency (% reduction in emissions) TSP (PM) - point Utility Flare N/A N/A PM,o - point Utility Flare N/A N/A PM2,5 - point Utility Flare N/A N/A TSP (PM) - fug. Speed limit, watering, paving N/A N/A PM10 - fug. Speed limit, watering, paving N/A N/A PM2,5 - fug. Speed limit, watering, paving N/A N/A SO„ Utility Flare N/A N/A NOx Utility Flare N/A N/A CO Utility Flare N/A N/A VOC Utility Flare 98% 98% Other; VOC Fug, LFG 75% 75% Form APCD-231 - Municipal Solid Waste Landfill l APEN • Revision 12/2016 6 I V CON4GAGG Permit Number: 97OPIA/E188 & 11WE1680 AIRS ID Number: 123 /0079 /009 & 013 [Leave blank unless APCD l as already assigned a permit # and AIRS ID] Section 7 (continued) From what year is the following reported actual annual emissions data? 2017 Use the following table to report the criteria pollutant emissions from source: Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant s Uncontrolled Emission Factor (Specify !!nits)etc) Emission i atr Source (AP -42, Mfg. Actual Annual Emissions requested annual Perms Emtssfon l_irialit(sjb , Uncontrolled (Tons/year) Controlled9 (Tons/year) Uncontrolled (Tons/year) ' Controlled (Tons/year) TSP (PM) - point PM90 - point 171b/mmscrmethane Permit No. melee° 1.1 4.5 PM2.5 - point TSP (PM) - fug. PM1p- fug. PM2,5 - fug. SO,t N/A AP -42 1.0 4.0 NO,t 681b/mmscfmethane Permit No. 11W51680 4.3 17.9 CO 370 Ib/mmscf methane Permit No. 11 WE1680 23,6 97.3 VOC N/A AP -42 40.78 10.3* 454.9 114.5* ' Actual Annual Other: ,• Requested Annual VAC Emissions a-102 Permit Emission Limits tons/year from fugitive a 114 tons/year from LFG and 0.1 tons/year fnm fugitive LFG and 0.5 the flare, ons/year from the flare. 6 Requested values will become permit limitations, Requested limit(s) should consider future process growth. If a control device is not specified, landfill gas emissions will be permitted to accommodate the maximum predicted landfill gas generation. Permit limits for flares will be based on the year with maximum emissions, even after landfill closure. The emission data above includes emissions from combustion sources listed in Section 6. 9 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non - criteria pollutants (e,g. HAP- hazardous air pollutant) emissions equal to or greater than 250 lbs/year? 0 Yes 0 No eport the non•criteria pollutant (HAP) emissions from source: • CAS Numbers Chemical Name overall Control Efficiency Uncontrolled Emission Factor (specify units) rector Source (AP-42Mfg. ) Uncontrolled Actual Emissions abs/year) Controlled Actual Emissions" (lbs/year) See attachment BThe emission data above includes emissions from combustion sources listed in Section 6. 9Mnual emission fees will be based on actual controlled emissions reported, If source has not yet started operating, leave blank. Form APCD-231 Municipal Solid Waste Landfill APEN • Revision 12/2016 7 I corua. t>ra Permit Number: 97OPWE188 & 11WE1680 AIRS ID Number: 123 /0079 / 009 & 013 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 9 - Fugitive Dust Control Measures Section 9A - Onsite Hauling, Loading and Unloading All Vehicles est. 20,000 15 25 app. 2,500. What is the maximum posted speed limit on the haul roads? 25 mph Which control measures are used for hauling, loading and unloading? (Check all that apply) ✓❑ Watering • Paved Surfaces r❑ Graveled Surfaces O Chemical Stabilizer ❑✓ Other (Specify): Maximum speed of 25 mph Section 9B - Soil Handling and Removal What is the maximum amount of soil handled at this landfill? 140,000 Which control measures are used for soil handling and removal? (Check all that apply) ✓❑ Watering O Moist Materials O Other (Specify): tons per year What is the total area of the site? What is the total disturbed area of the site? Section 9C - Disturbed Area 660 acres acres 175 Which control measures are used for the disturbed area? (Check all that apply) r❑ Watering r❑ Revegetation Compaction O Other (Specify): Form APCD-231 - Municipal Solid Waste Landfill APEN - Revision 12/2O16 IV, COLORADO 8 *I.nl�h 1.. Fn�•iinnrrv.u.� Permit Number: g7OPWE188 & 11WE1680 AIRS ID Number: 123 /0079 / 009 & Section 10 • Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct, Signature o Legally Authorized Person (not a vendor or consultant) Randy Tourville Name (print) District Manager Title Check the appropriate box to request a copy of the: ✓® Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised AP€N is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions Increase, increase production, new equipment, change in fuel type, etc), See Regulation No, 3, Part A, II,C. for revised APCN requirements. Send this form along with $152,90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-5S-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/aped Colorado Department of Public Health and Environment Telephone: (303) 692.3150 Hello