CORRESPONDENCE_2005-2006 - Laserfiche WebLink

Home Browse Search

7. "Collection System" is defined as the LFG collectors, whether vertical wells or horizontal wells, needed to comply with 40 CFR Part 60 or to prevent off-site migration per CCR Title 27, as well as the piping connecting these LFG collectors to the LFG flare station. Other regulatory agencies may require collection of soil gas or LFG from leachate risers. We ask that the requirements of this Permit apply to the LFG wells installed to meet the requirements of 40 CFR Part 60, and that collection from other items be exempt as long as (1) they are not needed to comply with 40 CFR Part 60, and (2) do not cause the design flow rate of the system to be exceeded. This provision coordinates with No. 12 and 13, below. 8. "Control System" is defined as the LFG flare and any equipment used to maintain proper operation of the flare. 9. "Maintenance" is defined as work performed on a gas collection system and/or control device in order to ensure continued compliance with District rules, regulations, and/or Permits to Operate, and to prevent its failure or malfunction. [District NSR Rule] Federally Enforceable Through Title V Permit. This was copied from a Stanislaus County AQMD Permit. 10. "Shutdown" is defined as the cessation of operation of the LFG collection and control system as defined in Rule 1100 for reasons other than loss of electrical service. We ask that the County not be held responsible for problems with the electrical grid. 11. "Startup" is defined as the activity of starting or attempting to start operation of the system, as well as measurements, manipulations ,operational adjustments, attempts to restore operation, and testing to verify proper operation of the LFG control system. Unsuccessful attempts to restart shall not be considered an individual shutdown. Permittee shall minimize emissions during startup. This condition addresses a lack of clarification that has caused some inspectors (in another jurisdiction) to consider a failed attempt to restart as a "shutdown" 12. Other sources of LFG, such as from leachate collection pipes or LFG collectors not required for compliance with this Permit, may be connected and to the LFG collection system and disconnected at the discretion of the Permittee. When in operation, such additional collection points shall be operated in accordance with this permit, including the limitation of flow rate to the LFG flare. Surface emissions tests will be made with these other sources not in operation. The well system proposed is designed to comply with all portions of 40 CFR Part 60 without collection from items not designed as LFG wells. We ask that we be allowed to collect additional LFG, possibly from areas that have not been filled for five years and therefore are not required to have collection per 40 CFR Section 60.753(x)(1), without causing the restrictions and reporting requirements to be imposed on those items as if they were part of the system needed to comply with 40 CFR Part 60. Leachate collection pipes or horizontal collectors not yet needed to comply with 40 CFR Part 60 would not be included in LFG collection system of this Permit. 13. Other gas collection points, such as soil gas trenches installed under the liner, soil gas extraction wells, or collectors of fugitive emissions, may be connected and to the LFG collection system and disconnected at the discretion of the Permittee, subject to the conditions of other permits as may apply. Operation of such other soil collection points Draft Permit Requirements Foothill Landfill LFG System Request for ATC 2 San Joaquin County