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<br /> <br /> <br />Memorandum <br />March 25, 2025 <br />Page 4 <br />21202-23 North County Landfill_AQ_0307 <br />ambient air quality standards but are regulated through state and local risk management <br />programs. <br />Unlike criteria air pollutants, which generally affect regional air quality, TAC emissions are <br />evaluated based on estimations of localized concentrations and risk assessments. The adverse <br />health effects a person may experience following exposure to any chemical depend on several <br />factors, including the amount (dose), duration, chemical form, and any simultaneous exposure <br />to other chemicals. <br />For risk assessment purposes, TACs are separated into carcinogens and non-carcinogens. <br />Carcinogens are assumed to have no safe threshold below which health impacts would not <br />occur, and cancer risk is expressed as excess cancer cases per 1 million exposed individuals over <br />a lifetime of exposure. Non-carcinogenic substances are generally assumed to have a safe <br />threshold below which health impacts would not occur. Acute and chronic exposure to non- <br />carcinogens is expressed as a hazard index, which is the sum of expected exposure levels <br />divided by the corresponding acceptable exposure levels. <br />Landfill Gas <br />Methane (CH4) and carbon dioxide (CO2) are the primary constituents of LFG and are produced <br />by the natural process of bacterial decomposition of organic material within the landfill under <br />anaerobic conditions. By volume, LFG is typically about 50 percent methane and 50 percent <br />carbon dioxide and water vapor. In addition to these main components, LFG contains small <br />amounts of nitrogen, oxygen, and hydrogen, less than 1 percent non-methane organic <br />compounds (NMOCs), and trace amounts of inorganic compounds. Some of these compounds <br />have strong, pungent odors (for example, hydrogen sulfide). <br />Volatile organic compounds (VOC), including approximately 30 TACs, have been identified in <br />uncontrolled LFG, including benzene, toluene, ethyl benzene, and vinyl chloride. Exposure to <br />these pollutants can lead to adverse health effects. Existing regulations under the Federal Clean <br />Air Act, as discussed below under Regulatory Setting, require landfills of a certain size to install <br />and operate a gas collection and control system. These regulations target municipal solid waste <br />(MSW) landfill emissions. The regulations require NMOCs to be measured as a surrogate for <br />LFG and owner/operators to collect and combust their LFG. <br />The rate of LFG generation is influenced by the amount of bioavailable carbon, the type of <br />material containing it, and the environmental conditions that support anaerobic bacterial <br />activity. As waste is continuously deposited in the landfill, LFG production gradually increases <br />throughout the landfill’s operational life, reaching its highest level on the final day of waste <br />disposal, often referred to as the landfill’s closure. After closure and capping, LFG generation <br />may decline further due to reduced moisture infiltration.