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February 5, 2007 Mr. Dylan Van Dyne, Air Quality Inspector San Joaquin Valley Unified Air Pollution Control District 4800 Enterprise Way Modesto, California 95356-8718 a P. O. BOX 1810 - 1810 E. HAZELTON AVENUE STOCKTON, CALIFORNIA 95201 (209) 468-3000 FAX (209) 468-2999 www.sjgov.org/pubworks SUBJECT: TIER 2 UPDATE, FOOTHILL SANITARY LANDFILI SJUAPCD PERMIT N-4070 Dear Mr. Van Dyne: VE DD FFR 0 -92007 E VJROAIEN1- MEALY ERMIT/sm'/CES Attached please find an update of the calculated emissions of volatile organic compound (VOC) emissions based on refuse placed through 2006 (Table 1). A landfill gas (LFG) collection system is required at this site in accordance with 40 CFR 60.752 due to the calculated potential to emit VOCs in excess of 50 Mg/yr in 2004. All increments of compliance for this system have been met on or before schedule. Construction of the LFG system was initiated in June 2006, approximately six months before the required increment deadline of January 2007. The next increment of compliance is the completion of construction and start of operation, due July 25, 2007. Most of the LFG system is now installed, but some adjustments of the piping will be required before we can begin full operation. The final increment is testing for surface emissions, due 180 days after the due date for the start of operation, or January 21, 2008. We intend to take a sample from the LFG header at that time to calculate the actual emissions per CFR Part 40 Section 60.754 (b). The regulations do not seem to require that we repeat this calculation unless we desire to discontinue operating the LFG system. Because the landfill will continue receiving refuse for many years, we do not anticipate that the potential to emit VOCs will decrease, and we probably will not repeat this calculation until after closure in 2059. Pursuant to 40CFR 60.757(b), we will be exempt from submitting annual NMOC emission rate reports once this system is in operation. Therefore this will be our final VOC emission estimate for the facility to show compliance with 40 CFR Section 60. Op4UIN'C q' ?< THOMAS R. FLINN DIRECTOR Cq CIFOFa�P THOMAS M. GAU CHIEF DEPUTY DIRECTOR MANUEL SOLORIO DEPUTY DIRECTOR STEVEN WINKLER DEPUTY DIRECTOR ROGER JANES BUSINESS ADMINISTRATOR February 5, 2007 Mr. Dylan Van Dyne, Air Quality Inspector San Joaquin Valley Unified Air Pollution Control District 4800 Enterprise Way Modesto, California 95356-8718 a P. O. BOX 1810 - 1810 E. HAZELTON AVENUE STOCKTON, CALIFORNIA 95201 (209) 468-3000 FAX (209) 468-2999 www.sjgov.org/pubworks SUBJECT: TIER 2 UPDATE, FOOTHILL SANITARY LANDFILI SJUAPCD PERMIT N-4070 Dear Mr. Van Dyne: VE DD FFR 0 -92007 E VJROAIEN1- MEALY ERMIT/sm'/CES Attached please find an update of the calculated emissions of volatile organic compound (VOC) emissions based on refuse placed through 2006 (Table 1). A landfill gas (LFG) collection system is required at this site in accordance with 40 CFR 60.752 due to the calculated potential to emit VOCs in excess of 50 Mg/yr in 2004. All increments of compliance for this system have been met on or before schedule. Construction of the LFG system was initiated in June 2006, approximately six months before the required increment deadline of January 2007. The next increment of compliance is the completion of construction and start of operation, due July 25, 2007. Most of the LFG system is now installed, but some adjustments of the piping will be required before we can begin full operation. The final increment is testing for surface emissions, due 180 days after the due date for the start of operation, or January 21, 2008. We intend to take a sample from the LFG header at that time to calculate the actual emissions per CFR Part 40 Section 60.754 (b). The regulations do not seem to require that we repeat this calculation unless we desire to discontinue operating the LFG system. Because the landfill will continue receiving refuse for many years, we do not anticipate that the potential to emit VOCs will decrease, and we probably will not repeat this calculation until after closure in 2059. Pursuant to 40CFR 60.757(b), we will be exempt from submitting annual NMOC emission rate reports once this system is in operation. Therefore this will be our final VOC emission estimate for the facility to show compliance with 40 CFR Section 60.