CORRESPONDENCE_2016-2017 - Laserfiche WebLink

Home Browse Search

E Dr. Andrew Altevogt December 15, 2017 Page 5 of 6 11 • The effective operation of the corrective action measures at LF -1, which consists of extraction and destruction of LFG, relies on the efficient handling of condensate. The current condensate handling procedure that has been implemented at FSL is state of the practice in which liquids are handled as a single source, even if LFG is extracted from lined or unlined units from the same MSW landfill. • Since both Federal and State MSW regulations allow for the discharge of condensate to a lateral expansion unit, the requirement to remove condensate from a landfill that has a unit with a compliant liner and leachate collection system could be considered onerous. In our professional opinion and with consultation with industry experts, return of condensate generated from LF -1 LFG system to LF -2 LCRS system is within applicable regulations and does not pose a threat to groundwater quality. Therefore, the County requests that LF -1 condensate continue to be allowed to be discharged into LF -2 in a manner that has occurred since 2006, and amend the new WDR to reflect this. OPTION 2 If Option 1 is not feasible, then the destruction of LF -1 condensate at the flare appears to be the most efficient and cost effective mechanism for the disposal of condensate. Although costly to construct, this option is more cost effective in the long run than off-site disposal of condensate. The cost to design, permit, procure, and install a new flare station at FSL is estimated to be $1.5 million. The existing flare is an open stack flare, which is only used as a backup to the gas -to -energy plant at the site, and is permitted only as a backup flare with San Joaquin Valley Air Pollution Control District (Air District) and is not equipped for condensate destruction. This capital cost is being added to the FSL's budget for 2018 Fiscal year. However, it will take upwards of one year for the design, air quality permitting, delivery, and installation of this new flare. Please see the attached schedule for the design, permitting, and construction of the new enclosed flare at FSL. OPTION 3 A lined evaporation pond for the condensate would potentially cause nuisance odors and emissions unlikely permitted by the Air District, and would require costly monitoring and reporting. The County can look into constructing a pond further, however this option would only be pursued if for whatever reason options 1 and 2 are not acceptable. Therefore, San Joaquin County requests that LF -1 condensate continued to be allowed to be discharged into LF -2 in a manner that has occurred since 2006, and amend the new WDR to reflect this as discussed above in Option 1. Otherwise the County requests an extension to WDR Discharge Specification B.6. from 15 October 2016 to 15 October 2019. This extension would allow San Joaquin County sufficient time to permit, contract for, and construct a new LFG flare at the FSL, as discussed above in Option 2. This extension will also allow San Joaquin County to focus more finances toward addressing its Title 27, WDR, and NOV requirements to reduce groundwater and vadose zone impacts versus spending monies on disposal of condensate offsite when there is an onsite disposal method previously approved.