CORRESPONDENCE_2005-2006 - Laserfiche WebLink

Home Browse Search

2 11 shall not cause the capacity of other permitted equipment to be exceeded, including the limit of the flow rate to the LFG flare. Other regulatory agencies may require that air be collected from soil gas trenches or wells, or the County may wish to collect odors from a leachate tank or other source of fugitive emissions. It would not be possible to operate these collection points in accordance with 40 CFR Part 60, therefore, we ask that such miscellaneous points not be considered part of the LFG collection system of this Permit. 14. Gas collection system shall be operated to comply with surface emission requirements while preventing overdraw that can cause fires or damage to the gas collection system. [District NSR Rule] Federally Enforceable Through Title V Permit. 15. Collection System Operation: 40 CFR Part 60 allows adjustment of operation under certain conditions. These suggested provisions clarify the application of those provisions. a. At individual wells needed for compliance, either nitrogen concentration shall not exceed 40% (v/v), or methane content shall not be less than 5% (v/v). 40 CFR Section 60.753(c) allows the operator to establish criteria other than those in that Section; however, the Nitrogen limit (20%) is unreasonably restrictive, and is not necessary to protect against fires. The proposed limit (40%) will allow the LFG system to be operated normally. b. Negative pressure shall be maintained on all portions of the collection system needed to comply with 40 CFR Section 60.753(d). Negative pressure need not be maintained on a well or collector which cannot maintain compliance with Requirement a or b above. 40 CFR Section 60.753 (b) lists exemptions to the requirement of maintaining negative pressure. One of these allows turning off a well in case of "declining flow". This provision is offered to clarify what condition might reflect declining flow. Note that at the Corral Hollow Landfill LFG system, some wells are found to have positive pressure and poor gas quality. At the same time, this site consistently passes Rule 4642 surface emissions tests and is in compliance with subsurface LFG migration standards. If such circumstances occur at the Foothill Landfill, we would want to turn off such wells as long as the surface emission requirements are met. 16. Measurement of gas quality at the LFG collectors and within the collection system piping shall be by portable gas meter suitable for that purpose, GEM 500 or equivalent. Section 60.753 allows the use of other measurement methods. The portable instrument proposed is a common instrument used in the LFG industry. 17. All LFG collected shall be combusted in the LFG flare. [District NSR Rule] Federally Enforceable Through Title V Permit. 18. The LFG Flare shall be operated within the range specified in 40 CFR Section 60.18 [District NSR Rule] Federally Enforceable Through Title V Permit. This ensures that 98% of NMOCs will be destroyed. Draft Permit Requirements Foothill Landfill LFG System Request for ATC 3 San Joaquin County