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11 <br />Environmental Consultants 6850 Regional Street 925 829-0661 <br />Suite 240 FAX 925 829-5493 <br />Dublin, CA 94568-2920 www.scseng.com <br />September 2, 1999 <br />File No. 1099017.00 <br />Ms. Sangeeta Lewis <br />Lewis Engineering <br />98 Ramona Avenue <br />Piedmont, California 94611 <br />SUBJECT: REVIEW OF REGULATORY COMPLIANCE FOR LANDFILL GAS EMISSIONS <br />AND MIGRATION CONTROL, FORWARD LANDFILL, WMU-B, <br />SAN JOAQUIN COUNTY, CALIFORNIA <br />Dear Ms. Lewis: <br />SCS Engineers (SCS) has reviewed information regarding the New Source Performance <br />Standards (NSPS) and landfill gas (LFG) perimeter monitoring network in order to determine <br />if the installation of a LFG collection and control system (GCCS) is necessary at the time of <br />closure for Waste Management Unit B (WMU-) at Forward Landfill, San Joaquin County, <br />California. We understand WMU-B closure is scheduled for year 2001. The following is a <br />summary of our findings. <br />NEW SOURCE PERFORMANCE STANDARDS <br />Under the NSPS, landfills that meet certain applicability criteria may be required to design <br />and install a GCCS. An exemption or deferral from this requirement can be obtained by <br />evaluating LFG emissions and demonstrating that said emissions are below specified <br />regulatory thresholds. <br />The Forward Landfill is considered an "existing" landfill under the NSPS because it received <br />waste after December 1987 and has additional design capacity to receive waste. As such, <br />it is subject to the NSPS Emission Guidelines (G). The EG has been promulgated into <br />regulation by the San Joaquin Valley Unified Air Pollution Control District (APCD). <br />The Tier 1 emission rate value was anticipated to exceed the non -methane organic <br />compound (NMOC) emission rate threshold of 50 Megagrams (approximately 55 tons) per <br />year. A Tier 1 study was prepared for the site and an NMOC emission rate was calculated <br />to be 152.7 Megagrams (Mg) per year for 1999, which is above the NSPS applicability <br />threshold. However, an NSPS Tier 2 testing program allows the determination, through <br />sampling and analysis of LFG, of a site-specific NMOC concentration. The site-specific value <br />can then be used in the U.S. EPA's emission rate equation in lieu of the Tier 1 default value, <br />and a new NMOC emission rate can be calculated. <br />SCS conducted the Tier 2 investigation for the site on December 15 and 16, 1998 in order <br />to obtain a site-specific NMOL concentration. Using the U.S. EPA Landfill Air Emissions <br />Estimation Model, the estimated NMOC emissions rate for 1999 was 19.92 Mg/yr and in <br />five years (2004) was estimated to be 27.14Mg/yr. Because estimated NMOC emissions <br />Offices Nationwide <br />