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E <br />E <br />Based on the NSPS method for estimating the potential maximum non -methane organic <br />compound (NMOC) emission rate, the Foothill Landfill will exceed the 50 mega grams <br />per year (Mg/yr) threshold due to refuse placed in 2004 and is therefore required to <br />comply with §60.752(b)(2) of the NSPS. <br />4.7.1 Submit a Design Plan <br />§60.752(b)(2)(i) Submit a collection and control system design plan <br />prepared by a professional engineer to the Administrator within I year. <br />This Design Plan is submitted in accordance with this requirement. <br />4.7.2 Alternatives to the NSPS <br />§60.752(b)(2)(i)(B) The collection and control system design plan shall <br />include any alternatives to the operational standards, test methods, <br />procedures, compliance measures, monitoring, record keeping or <br />tV6rt1ng prov&ians'of §66 753 through 60 758 proposed ray the owner <br />or operator. <br />§60.752(b)(2)(I)(B) provides that the GCCS design plan can include alternatives to the <br />requirements of §60.753 through §60.758. Alternative operational criteria for the Foothill <br />Landfill are described below, and are incorporated into the Draft Permit Unit <br />Requirements proposed by San Joaquin County: <br />Decommissioning of wells <br />§60.753(b)(3) Allows for the decommissioning of wells. It is proposed <br />that landfill operations staff be granted the authority to decommission any <br />well which, while under significant vacuum is unable to collect a <br />significant amount of gas as defined below, so long as compliance with <br />§60.753(b)(4) is retained. All decommissioned wells will be recorded in <br />the operating records. <br />Significant amount of gas shall be defined as greater than 1% of the total <br />flow of the landfill gas collection system. <br />Allowable N2 in the Collected LFG <br />Air intrusion into the LFG wells will be controlled by well design, <br />construction and operation and landfill maintenance. If the system <br />operates outside the NSPS operational limits for N2 in the collected LFG, <br />the LFG system operator will monitor the gas wells to verify no unusual <br />circumstances are occurring that could lead to a landfill fire. The primary <br />indicator is an increase in gas temperature. Other indicators could be CO <br />Foothill Sanitary Landfill 16 Public Works/Solid Waste <br />LFG CS Design Plan County of San Joaquin - March 10, 2005 <br />