march 22, 2019. direct comments, in writing, to the north ... · ignition internal combustion...

NOTICE OF INTENT TO ISSUE AN

AIR POLLUTION CONTROL

PERMIT TO CONSTRUCT

Take notice that the North Dakota Department of Health proposes to issue an Air Pollution ControlPermit to Construct to the City of Dickinson in accordance with the North Dakota Air PollutionControl Rules. The project involves the addition of a new air curtain destructor to bum cleanwood at the Dickinson Sanitary Landfill located at SE Va, Sec. 17, Twp. 139N, R. 95W in StarkCounty, ND.

A 30-day public comment period for the proposed permit will begin April 23, 2019 and end onMarch 22, 2019. Direct comments, in writing, to the North Dakota Department of Health,Division of AirQuality, 918 E Divide Avenue, Bismarck, ND 58501-1947 or [email protected] must be receivedduring the publiccommentperiod to be considered in the final permitdetermination.

A public meetingregarding issuance of the Permit to Constructwill be held if a significant degreeof public interestexists as determined by the Department. Requests for a public meetingmust bereceived in writing by the Department before the end of the public comment period. Theapplication, Department analysis and draft permit are available for review at the above address andon-lineat httD://www.deQ.nd.gov/AO/PublicCom.aspx#DSL. A copy ofthese documentsmay beobtained by writing to the Division of Air Quality or contacting Rheanna Kautzman at(701)328-5188 or by email at [email protected].

Dated this 18'*^ day of April 2019

Jim Semerad

Director

Division of Air Quality

tNORTH DAKOTA

DEPARTMENTo/ HEALTH

ENVIRONMENTAL HEALTH SECTIONGold Seal Center, 918 E. Divide Ave.

Bismarck, ND 58501-1947701.328.5200 (fax)www.ndhealth.gov

AIR POLLUTION CONTROL

PERMIT TO CONSTRUCT

Pursuant to Chapter 23.1-06 of the North Dakota Century Code, and the Air Pollution ControlRules of the State of North Dakota (Article 33.1-15 of the North Dakota Administrative Code),and in reliance on statements and representations heretofore made by the owner designated below,a Permit to Construct is hereby issued authorizingsuch owner to construct and initiallyoperate thesource unit(s) at the location designated below. This Permit to Construct is subject to allapplicable rules and orders now or hereafter in effect of the North Dakota Department of Healthand to any conditions specified below:

I. General Information:

A. Permit to Construct Number: PTC19017

B. Source:

1. Name:

2.

3.

4.

Dickinson Sanitary LandfillLocation: SE '/4, S17, T139N, R95W

3880 Lehigh RoadDickinson, North Dakota 58601Stark County

Source Type: LandfillExisting Equipment (Landfill was previously exempt from needing toobtain an Air Quality Permit):

Emission Unit DescriptionEmission

Unit (EU)

Emission

Point (EP)Air Pollution Control

EquipmentMunicipal solid waste landfillwith a total waste capacity of2.81 X10^ m^ (WWW, XXX)

1 1 None

Fugitive dust emissions FUG FUG Fugitive Dust Control

5. Equipment to be added:


Unit (EU)Emission


Equipment

Air Curtain Destructor rated

up to 7 tons/hr (CCCC)2 2 None

Air Curtain Destructor Diesel-

Fired Engine (IIII)3* 3

Diesel Oxidation

Catalyst

Environmental Health

Section Chiefs Office

701.328.5150

Certified Tier 4 Engine, per 40 CFR 60, Subpart IIII.

Division of

Air Quality701.328.5188

Division of

Municipal Facilities701.328.5211

Printed on recycled paper.

Division of

Waste Management701.328.5166

Division of

Water Quality701.328.5210

of 8Permit No. PTC19017

C. Owner/Operator (Permit Applicant):

1. Name: City of Dickinson2. Address: 3411 Public Works Blvd

Dickinson, North Dakota 586013. Application Date: February 19,2019

II. Conditions: This Permit to Construct allows the construction and initial operation of theabove-mentioned new or modified equipment at the source. The source may be operatedunder this Permit to Construct until a Permit to Operate is issued unless this permit issuspended or revoked. The source is subject to all applicable rules, regulations, and ordersnow or hereafter in effect of the North Dakota Department ofHealth and to the conditionsspecified below.

A.

B.

C.

D.

Enoiission Limits: Emission limits from the operation of the new equipmentidentified in Item LB of this Permit to Construct (hereafter referred to as "permit")are as follows. Minor source units not listed are subject to the applicable emissionlimits specified in the North Dakota Air Pollution Control Rules.

Emission Unit

Description EU EP

Pollutant /

Parameter Emission Limits

Air Curtain

Destructor2 2

Opacity(Start-up)

And

Opacity(all other times)

<35% within the V 30-

minutes of operation

And

<10% other than start

up

Air Curtain

Destructor

Generator

Engine

3 3 Opacity 20%'

Permissible br not more than one six-minute period per hour.

Fuel Restriction: The engine (EU 3) is restricted to combusting only restricted tocombusting only distillate oil containing no more than 0.0015 percent sulfur byweight.

Startup Notice: A notification of the actual date of initial startup shall besubmitted to the Department within 15 days after the date of initial startup.

Emissions Testing: (Note: all initial testing will require a minimum of 3 runs,one hour each, unless otherwise specified in a federal subpart).

of 8Permit No. PTC19Q17

1. Initial Testing: Within 180 days after initial startup, the permittee shallconduct emissions tests at the emission units listed below using anindependent testing firm, to determine the compliance status of the facilitywith respect to the emission limits specified in Condition II.A. Emissionstesting shall be conducted for the pollutant(s) listed below in accordancewith EPA Reference Methods listed in 40 CFR 60, Appendix A. Testmethods other than those listed below may be used upon approval by theDepartment.

Emission Unit

Description EP

Pollutant/

Parameter Method

Air Curtain

Destructor2 Opacity 9

A signed copy of the test results shall be furnished to the Department within60 days of the test date. The basis for this condition isNDAC 33.1-15-01-12 which is hereby incorporated into this permit by reference. To facilitatepreparing for and conducting such tests, and to facilitate reporting the testresults to the Department, the owner/operator shall follow the proceduresand formats in the Department's Emission Testing Guideline.

2. Notification: The permittee shall notify the Department using the form inthe Emission Testing Guideline, or its equivalent, at least 30 calendar daysin advance of any tests of emissions of air contaminants required by theDepartment. If the permittee is unable to conduct the performance test onthe scheduled date, the permittee shall notify the Department at least fivedays prior to the scheduled test date and coordinate a new test date with theDepartment.

3. Sampling Ports/Access: Sampling ports shall be provided downstream ofall emission control devices and in a flue, conduit, duct, stack or chimneyarranged to conduct emissions to the ambient air.

The ports shall be located to allow for reliable sampling and shall beadequate for test methods applicable to the facility. Safe samplingplatforms and safe access to the platforms shall be provided. Plans andspecifications showing the size and location of the ports, platform andutilities shall be submitted to the Department for review and approval.

4. Other Testing:

a) The Department may require the permittee to have tests conductedto determine the emission of air contaminants from any source,whenever the Department has reason to believe that an emission ofa contaminant not addressed by the permit applicant is occurring, orthe emission of a contaminant in excess of that allowed by thispermit is occurring. The Department may specify testing methodsto be used in accordance with good professional practice. The


Department may observe the testing. All tests shall be conductedby reputable, qualified personnel. A signed copy of the test resultsshall be furnished to the Department within 60 days of the test date.

All tests shall be made and the results calculated in accordance with

test procedures approved by the Department. All tests shall bemade under the direction of persons qualified by training orexperience in the field of air pollution control as approved by theDepartment.

b) The Department may conduct tests ofemissions of air contaminantsfrom any source. Upon request of the Department, the permitteeshall provide necessary holes in stacks or ducts and such other safeand proper sampling and testing facilities, exclusive of instrumentsand sensing devices, as may be necessary for proper determinationof the emission of air contaminants.

E. New Source Performance Standards (NSPS): The owner/operator shall complywith all applicable requirements of the following NSPS subparts as referenced in

Chapter 33.1-15-12 of the North Dakota Air Pollution Control Rules and 40 CFR60:

1. Subpart WWW - Standards of Performance for Municipal Solid WasteLandfills (EU 1).

2. Subpart XXX - Standards of Performance for Municipal Solid WasteLandfills That Commenced Construction, Reconstruction, or ModificationAfter July 17, 2014 (EU 1). The North Dakota Department of Health hasnot adopted this subpart. Please send all documentation to EPA at thefollowing address:

U.S. EPA Region 81595 Wynkoop StreetMail Code 8ENF-AT

Denver, CO 80202-1129

3. Subpart CCCC—Standards of Performance for Commercial and IndustrialSolid Waste Incineration Units (EU 2).

4. Subpart IIII— Standards of Performance for Stationary CompressionIgnition Internal Combustion Engines (EU 3).

F. National Emission Standards for Hazardous Air Pollutants (NESHAP): Thepermittee shall comply with all applicable requirements of the following NDAC33.1-15-13 and 40 CFR 61 subparts, in addition to complying with Subpart A -General Provisions.


1. Subpart M - National Emission Standard for Asbestos (EU 1).

G. Maximum Achievable Control Technology (MACT): The owner/operator shallcomply with all applicable requirements of the following MACT subparts asreferenced in Chapter 33.1-15-22 of the North Dakota Air Pollution Control Rulesand 40 CFR 63:

1. 40 CFR 63, Subpart ZZZZ: The owner/operator must comply with allapplicable requirements of 40 CFR 63, Subpart ZZZZ - National EmissionStandard for Hazardous Air Pollutants for Stationary Reciprocating InternalCombustion Engines. The North Dakota Department of Health has notadopted the area source provisions of this subpart. All requireddocumentation must be submitted to EPA Region 8 EPA at the addresslisted above (EU 3).

H. Storage Tanks: All stationary volatile organic compound storage tanks shall beequipped with a submerged fill pipe in accordance with NDAC 33.1-15-07-01.3.

I. Like-Kind Engine Replacement: This permit allows the permittee to replace anexisting generator engine with a like-kind engine. Replacement is subject to thefollowing conditions:

1. The Department must be notified within 10 days after change-out of theengine.

2. The replacement engine shall operate in the same manner, provide noincrease in throughput and have equal or less emissions than the engine it isreplacing.

3. The date of manufacture of the replacement engine must be included in thenotification. The facility must comply with any applicable federalstandards (e.g. NSPS, MACT) triggered by the replacement.

The replacement engine is subject to the same state emission limits as the existingengine in addition to any NSPS or MACT emission limit that is applicable.

J. Title V Permit to Operate: Within one year after the issuance of this Permit toConstruct, the owner/operator shall submit a permit applicMion for a Title V Permitto Operate for the facility.

K. Permit Invalidation: This permit shall become invalid if construction is notcommenced within eighteen months after issuance of such permit, if constructionis discontinued for a period of eighteen months or more; or if construction is notcompleted within a reasonable time.


L. Fugitive Emissions: The release of fugitive emissions shall comply with theapplicable requirements in NDAC 33.1-15-17.

M. Annual Emission Inventory/Annual Production Reports: The owner/operatorshall submit an annual emission inventory report and/or an annual production reportupon Department request, on forms supplied or approved by the Department.

N. Source Operations: Operations at the facility shall be in accordance withstatements, representations, procedures and supporting data contained in the initialapplication, and any supplemental information or application(s) submittedthereafter. Any operations not listed in this permit are subject to all applicableNorth Dakota Air Pollution Control Rules.

O. Alterations, Modifications or Changes: Any alteration, repairing, expansion, orchange in the method ofoperation of the source which results in the emission of anadditional type or greater amount ofair contaminants or which results in an increasein the ambient concentration of any air contaminant, must be reviewed andapproved by the Department prior to the start of such alteration, repairing,expansion or change in the method of operation.

P. Air Pollution from Internal Combustion Engines: The permittee shall complywith all applicable requirements ofNDAC 33.1-15-08-01 - Internal CombustionEngine Emissions Restricted.

Q. Recordkeeping: The owner/operator shall maintain any compliance monitoringrecords required by this permit or applicable requirements. The owner/operatorshall retain records of all required monitoring data and support information for aperiod of at least five years from the date of the monitoring sample, measurement,report or application. Support information may include all calibration andmaintenance records and all original strip-chart recordings/computer printouts forcontinuous monitoring instrumentation, and copies of all reports required by thepermit.

R. Nuisance or Danger: This permit shall in no way authorize the maintenance of anuisance or a danger to public health or safety.

S. Malfunction Notification: The owner/operator shall notify the Department assoon as possible during normal working hours of any malfunction which can beexpected to last longer than twenty-four hours and can cause the emission of aircontaminants in violation of applicable rules and regulations. Immediatenotification to the Department is required for any malfunction that would threatenhealth or welfare, or pose an imminent danger.

T. Operation of Air Pollution Control Equipment: The owner/operator shallmaintain and operate all air pollution control equipment in a manner consistent withgood air pollution control practice for minimizing emissions.

of 8Permit No. PTC19Q17

U. Transfer of Permit to Construct; The holder of a permit to construct may nottransfer such permit without prior approval from the Department.

V. Right of Entry: Any duly authorized officer, employee or agent of the NorthDakota Department of Health may enter and inspect any property, premise or placeat which the source listed in Item LB of this permit is located at any time for thepurpose ofascertaining the state ofcompliance with the North Dakota Air PollutionControl Rules. The Department may conduct tests and take samples of aircontaminants, fuel, processing material, and other materials which affect or mayaffect emissions of air contaminants from any source. The Department shall havethe right to access and copy any records required by the Department's rules and toinspect monitoring equipment located on the premises.

W. Other Regulations: The owner/operator of the source unit(s) described in ItemI.B of this permit shall comply with all State and Federal environmental laws andrules. In addition, the owner/operator shall comply with all local burning, fire,zoning, and other applicable ordinances, codes, rules and regulations.

X. Permit Issuance: This permit is issued in reliance upon the accuracy andcompleteness of the information set forth in the application. Not withstanding thetentative nature of this information, the conditions of this permit herein become,upon the effective date of this permit, enforceable by the Department pursuant toany remedies it now has, or may in the future have, under the North Dakota AirPollution Control Law, NDCC Chapter 23.1-06.

Y. Odor Restrictions: The owner/operator shall not discharge into the ambient airany objectionable odorous air contaminant which is in excess of the limitsestablished in NDAC 33.1-15-16.

The owner/operator shall not discharge into the ambient air hydrogen sulfide (H2S)in concentrations that would be objectionable on land owned or leased by thecomplainant or in areas normally accessed by the general public. For the purposeof complaint resolution, two samples with concentrations greater than 0.05 partsper million (50 parts per billion) sampled at least 15 minutes apart within a two-hour period and measured in accordance with Section 33.1-15-16-04 constitute aviolation.

Z. Sampling and Testing: The Department may require the owner/operator toconduct tests to determine the emission rate of air contaminants from the source.

The Department may observe the testing and may specify testing methods to beused. A signed copy of the test results shall be furnished to the Department within60 days of the test date. The basis for this condition is NDAC 33.1-15-01-12which is hereby incorporated into this permit by reference. To facilitate preparingfor and conducting such tests, and to facilitate reporting the test results to the


Department, the owner/operator shall follow the procedures and formats in theDepartment's Emission Testing Guideline.

Date By

FOR THE NORTH DAKOTA

DEPARTMENT OF HEALTH

Jim Semerad

Director

Division ofAir Quality

NORTH DAKOTA

DEPARTMENTo/ HEALTH

ENVIRONMENTAL HEALTH SECTION

Gold Seal Center, 918 E. Divide Ave.Bismarck, ND 58501-1947

701.328.5200 (fax)www.ndhealth.gov

Air Quality Effects Analysisfor

Permit to Construct

PTC19017 (Preliminary)

I. Date of Review:April 10, 2019 (Preliminary)

II. Applicant:

City of Dickinson3411 Public Works Blvd

Dickinson, North Dakota 58601

III. Source Location:

Dickinson Sanitary LandfillSE'/4,S17,T139N,R95W3880 Lehigh RoadDickinson, North Dakota 58601Stark County

IV. Introduction and Background:

Dickinson Sanitary Landfill is and existing municipal landfill planning an expansion that wouldbring itstotal waste capacity to2.81x10^ m^ which isover the 2.5 x 10^ m^ threshold that triggersNSPS WWW and XXX applicability which require a Part 70 (Title V) Permit to Operate. Alongwith their initial Title V Permit to Operate application they also request to install an air curtaindestructor. This air curtain destructor requires a permit to construct.

Existing emission units at the facility:Under North Dakota Air Pollution Control Rules, a Municipal Solid Waste Landfill is not requiredto obtain an Air Quality Permit to Construct prior to operations (EU 1 and FUG).

Table J-Existing Equipment List


Unit (EU)Emission


Equipment

Municipal solid waste landfill witha total waste capacity of 2.81 x 10^m^ (proposed total capacity withexisting and expansion)

1 1 None

Air Curtain Destructor rated up to7 tons/hr (CCCC)

2 2 None

Environmental Health

Section Chiefs Office

701.328.5150

Division of

Air Quality701.328.5188

Division of

Municipal Facilities701.328.5211

Printed on recycled paper.

Division of

Waste Management701.328.5166

Division of

Water Quality701.328.5210


Unit (EU)Emission


EquipmentAir Curtain Destructor Diesel-

Fired Engine (IIII) 3 3 Diesel Oxidation Catalyst

Fugitive dust emissions FUG FUG Fugitive Dust Control

V. Potential to Emit (PTE) Emissions

Emissions from the facility are as follows:

Table 2-PTE Calculations (in ions per year) ^

Facility-wideEmissions

EU PM/PM10/PM2.5 NOx CO SO2 VOCs

Municipal solidwaste landfill with

a total waste

capacity of 2.81 x10^ m^

1 — — — —

0.46

(1.18 NMOC)

Air Curtain

Destructor Model

AirBumers S-

119R rated at 5

tons/hr

2 3.61/0.14/0.07 6.00 91.54 4.95 2.10

Air Curtain

Destructor Diesel-

Fired Engine HatzH-Series Model

3H50TIC

3 0.01/0.01/0.01 1.45 2.03 ~ 0.46

Total w/o fugitives 3.62/0.15/0.08 7.45 93.57 4.95 3.02

Pollutants are abbreviated as follows:

PM: particulate matterPMio: particulate matter under 10 microns (<10 jig), includes PM2.5.PM2.5: particulate matter under 2.5 microns (<2.5 |ig)SO2: sulfur dioxideNOx: nitrogen oxidesVOC: volatile organic compoundsCO: carbon monoxide

Table 3-PTE Calculations (in tons peryear)

Facility-wideEmissions

EULargest Single

HAP^Total HAPs

TOTAL

COMBINED

FACILITY HAPS

Municipal solidwaste landfill with

a total waste

capacity of 2.81 x10®

1Tolune

0.501.48

Air Curtain

Destructor 2

Hydrogenchloride

4.33

8.66

10.15

Air Curtain

Destructor Diesel-

Fired Engine3

Tolune

4.08 X 10-30.012

^ HAPs: hazardousair pollutants as defined in Section 112(b)of the Clean Air Act Amendmentsof 1990

See application for more detailed emission calculations.

VI. Applicable Standards


Unit(EU)Applicable Standards

Municipal solid waste landfillwith a total waste capacity of2.81 X 10^ m^

1

33.1-15-12, Subpart WWW40 CFR 60, Subpart XXX

33.1-15-13, Subpart M

Air Curtain Destructor 2 33.1-15-12, Subpart CCCC

Air Curtain Destructor Diesel-

Fired Engine3

33.1-15-03-02

33.1-14-12, Subpart IIII40 CFR 63, Subpart ZZZZZ

Fugitive dust emissions FUG33.1-15-03-03

33.1-15-17

The Department has not adopted the area requirements of this subpart; EPA Region 8 isthe implementing and enforcement authorityfor this subpartat minor sourcesof hazardousair pollutants.The Department has not adopted this subpart; all required documentation should be sent toEPA Region 8.

A. NDAC 33.1-15-02-Ambient Air Quality Standards

The facility must comply with the Ambient Air Quality Standards (AAQS). Otherrequirements of this chapter include general prohibitions against harming health, causingdamage to plants, animals, other property and visible degradation. In addition to thesestandards, compliance with the Department's Air Toxics Policy is required.

Expected Compliance

The facilities greatest criteria pollutant is CO and all other criteria pollutants are below 10tpy, so compliance with the AAQS is expected

Total combined HAP emissions are low at 10.15 tons per year, with compliance withapplicable NSPS/MACT standards the facility is expected to comply with the ambient airquality standards and theAir Toxics Policy^.

B. NDAC 33.1-15-03-Restriction of Emission of Visible Air Contaminants

This chapter restricts the amount of visible air contaminants primarily particulate matter,from incinerators and fiiel-buming units.

Expected Compliance

The facility has one fuel-burning unit (EU 3) subject to this chapter. Opacity requirementsfor each applicable unit are listed in Table 4-Opacity Limits. Based on the fuels used,visible air emissions are expected to be well below the 20% opacity limit established bythis chapter.

Table 4-Opacity Limits

Emission Unit Description EUPollutant/

ParameterEmission Limit

Air Curtain Destructor Generator

Engine3 Opacity 20% (40%A)

^ Permissible for not more than one six-minute period per hour.

C. NDAC 33.1-15-06-Emissions of Sulfur Compounds Restricted

This chapter applies to any installation in which fuel is burned in which the SO2emissionsare substantially due to the sulfur content of the fuel burned and in which the fuel is burnedprimarily to produce heat. This chapter is not applicable to installations which are subjectto a SO2 emission limit under Chapter 33.1-15-12, Standards for Performance for NewStationary Sources, or installations which bum pipeline quality natural gas.

' August25, 2010 NDDoHPolicyfor the Control ofHazardousAir Pollutant (HAP) Emissions in ND (aka AirToxicsPolicy), httDs://deQ.nd.gov/Dublications/AO/Dolicv/Modeling/Air Toxics Policv.pdf

Expected Compliance

The engine (EU 3) is restricted to combusting only restricted to combusting only distillateoil containing no more than 0.0015 percent sulfur by weight.

D. NDAC 33.1-15-12-Standards of Performance for New Stationary Sources [40 Codeof Federal Regulations Part 60 (40 CFR Part 60)1

This chapter adopts most the Standards of Performance for New Stationary Sources(NSPS) under 40 CFR Part 60. The facility is subject subparts listed in Table 5 under 40CFR Part 60 which have been adopted by North Dakota.

Emission Unit Description Emission

Unit (EU)Applicable Standards

Municipal solid waste landfill 1NSPS WWW (NDAC 33.1-15-12)NSPS XXX (NDAC 33.1-15-12)

Air Curtain Destructor 2 NSPS CCCC (NDAC 33.1-15-12)

Air Curtain Destructor

Generator Engine 3 NSPS IIII (NDAC 33.1-15-12)

The Department has not adopted the area requirements of this subpart; EPA Region8 is the implementing and enforcement authority for this subpart at minor sourcesof hazardous air pollutants.The Department has not adopted this subpart; all required documentation should besent to EPA Region 8.

Subpart A-General Provisions

The facility is subject to one or more NSPS (NDAC 33.1-15-12/40 CFR 60) and issubject to this subpart, compliance is expected.

Expected Compliance

Subpart A contains the NSPS General Provisions, compliance with therequirements of Subpart A is expected through compliance with each applicableNSPS subpart.

Subpart WWW - Standards of Performance for Municipal Solid WasteLandfills

This subpart applies to reach municipal solid waste landfill that commencedconstruction, reconstruction, or modification after May 30, 1991 and have a designcapacity of 2.5 x 10^ m^ or greater. This subpart establishes emission limits andcontrol requirements on landfill gas.

Expected Compliance

The landfill is subject to the emission limits and control requirements of thissubpart. Control requirements are based on a tiered calculation methodology. Tier1 is a conservative emissions calculation; if Tier 1 methods indicate that Non-MethaneVOC (NMVOC)emission may be above 50 Mg/year, then Tier 2 requirestesting to determine if emissions exceed the 50 Mg/year threshold requiringcontrols. The Dickinson Landfill's Tier 1 calculations do not exceed 50 Mg/year.

3. Subpart XXX - Standards of Performance for Municipal Solid Waste LandfillsThat Commenced Construction, Reconstruction, or Modification After July17,2014

This subpart applies to reach municipal solid waste landfill that commencedconstruction, reconstruction, or modificationafter July 17, 2014 and have a designcapacity of 2.5 x 10^ m^ or greater. This subpart establishes emission limits andcontrol requirements on landfill gas.

Expected Compliance

The landfill is subject to the emission limits and control requirements of thissubpart. Control requirements are based on a tiered calculation methodology. Tier1 is a conservative emissions calculation; if Tier 1 methods indication that Non-Methane VOC (NMVOC) emissionmay be above 35 Mg/year, then Tier 2 requirestesting to determine if emissions exceed the 35 Mg/year threshold requiringcontrols. The Dickinson Landfill's Tier 1 calculations exceeded 35 Mg/year, sothey will conduct Tier 2 emissions testing to determine if controls are required forthe facility.

This facility appears to have requirements under this subpart. The North DakotaDepartment of Health has not adopted this subpart. All documentation should besent to EPA Region 8.

4. Subpart CCCC - Standards of Performance for Commercial and IndustrialSolid Waste Incineration Units

This subpart applies to new commercial and industrial solid waste incineration(CISWI), constructed, modified, or reconstructed after August 7, 2013.

Expected Compliance

The air curtain destructor is subject to this Subpart. Only clean wood productsmay be combusted, and the unit is subject to opacity limits.

Emission

Unit

Description EU

Pollutant /

Parameter Emission Limits ^ Requirements

Air Curtain

Destructor2

Opacity(Start-up)

And

Opacity(all other

times)

<35% within the V 30-

minutes of operation

And

<10% other than start-up

Opacity Method9 testingannually.

5. Subpart IIII - Standards of Performance for Stationary CompressionIgnition Internal Combustion Engines

This subpart applies to compression ignition engines- Constructed (ordered) after July 11,2005, and manufactured after April 1,2006

(July 1, 2006 for fire pump engines), or- Modified or reconstructed after July 11, 2005.- Except for engines >30 liters per cylinder (1/cyl) displacement, performance

testing is not required - you achieve compliance by:- purchasing a new engine that has been certified by EPA, and- installing, configuring, operating, and maintaining the engine per the

manufacturer's instructions.

Expected Compliance

This unit is an EPA certified engine and has no testing requirements.

Emission Unit

Description EU Requirements


Generator Engine3

Certified Engine, Tier 3

- Operate/maintain engine & control deviceper manufacturer's instructions or owner-developed maintenance plan.

- May use oil analysis program instead ofprescribed oil change frequency.

- Engines must have hour meter and recordhours of operation.

- Keep records of maintenance.- Reporting and ULSD for emergency

engines used for local reliability.

Compliance with this subpart is expected.

E. NDAC 33J-15-13-Emission Standards for Hazardous Air Pollutants [40 Code of

Federal Regulations Part 61 (40 CFR Part 61)1

This chapter adopts most the National Emission Standards for Hazardous Air Pollutants(NESHAP) under 40 CFR Part 61. The facility does not appear to have any applicablerequirements under this chapter.

Table 11 -Applicable NESHAP


Unit(EU)Applicable Standards

Municipal solid waste landfill 1 NESHAP M (NDAC 33.1-15-13)

The Department has not acopted the area requirements of this subpart; EPA Region8 is the implementing and enforcement authority for this subpart at minor sourcesof hazardous air pollutants.

® The Department has not adoptedthis subpart; all requireddocumentation should besent to EPA Region 8.

1. Subpart A-General Provisions

The facility is subject to one or more NESHAP (NDAC 33.1-15-13/40 CFR 61)and is subject to this subpart, compliance is expected.

Expected Compliance

Subpart A contains the NSPS General Provisions, compliance with therequirements of Subpart A is expected through compliance with each applicableNSPS subpart.

2. Subpart M - National Emission Standard for Asbestos

This subpart regulates the manufacture, handling, and despoil of asbestoscontaining materials. Active waste disposal sites are a facility subject to thissubpart.

Expected Compliance

The Dickinson Sanitary Landfill accepts asbestos containing waste and mustcomply with the requirements of this subpart.

F. NDAC 33,1-15-14-Designated Air Contaminant Sources, Permit to ConstructMinor Source Permit to Operate, Title V Permit to Operate

This chapter requires the facility to obtain a Permit to Construct prior to installation ofsources of air pollution. This chapter also applies to Permit to Operate requirements forfacilities that have sources of air pollution.

Expected Compliance

The facility has submitted an application for modifications to the facility and has alreadysubmitted an initial Title V Permit to Operate.

A 30-day public comment period is required under NDAC 33.1-15-14-02.6.a.(2) sinceNSPS CCCC does not exempt the air curtain destructor from the requirement to obtain aTitle V permit to operate.

G. NDAC 33.1-15-17-Restriction of Fugitive Emissions

This chapter requires the control of fugitive emissions.

Expected Compliance

Fugitive dust emissions are required to be mitigated as needed via watering or othermethods of dust control.

H. NDAC 33.1-15-22-Emissions Standards for Hazardous Air Pollutants for Source

Categories [40 Code of Federal Regulations Part 60 (40 CFR Part 63)]

Table V-MACT Requirements

Emission Unit

DescriptionEmission

Unit (EU)Applicable Standards


Diesel-Fired Engine HatzH-Series Model 3H50TIC

3B MACT ZZZZ rEPA^l (NDAC 33.1-15-22)

^ The Department has not adoptedthe area requirements of this subpart;EPA Region8 is the implementing and enforcement authority for this subpart at minor sourcesof hazardous air pollutants.

® The Department has not adoptedthis subpart; all requireddocumentation should besent to EPA Region 8.

1. Subpart A - General Provisions

This chapter adopts the 40 CFR Part 63 regulations, also known as the MaximumAchievable Control Technology (MACT) standards, which regulates hazardous airpollutants (HAPs) from regulated source categories. Typically, these standardsapply to major sources of air pollution that are a regulated source category. Inaddition to the major source requirements, some of the regulations have "areasource" standards (for non-major sources). Some of the area source standards havenot been adopted by the Department and compliance will be determined by theUnited States Environmental Protection Agency (USEPA) (e.g. 40 CFR Part 63,Subpart ZZZZ area source provisions have not been adopted by the Department).

Expected Compliance

Subpart A contains the MACT General Provisions, compliance with therequirements of Subpart A is expected through compliance with each applicableMACT subpart.

2. Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutantsfor Stationary Reciprocating Internal Combustion Engines

The facility appears to have an engine subject to the requirements under thissubpart. The requirements of Subpart ZZZZ for the engines are met by complyingwith the requirements of NDAC 33.1-15-12 [40 CFR 60], Subpart IIII.

Expected Compliance

The Department has not adopted Subpart ZZZZ at area sources such as this facility.EPA Region 8, not the North Dakota Department of Health, is the implementingand enforcement authority. All required documentation must be submitted to EPARegion 8.

Table 8-MACT ZZZZ Requirements

Emission Unit

DescriptionEmission

Unit(EU)Requirements


Diesel-Fired Engine HatzH-Series Model 3H50TIC

3 Comply withNSPS IIII

VII. Summary:

It is recommended that PTC for the new air curtain destructor and associated engine be put out for30-day public comment, prior to making a final determination on issuance for City of Dickinson'sDickinson Sanitary Landfill.

VIII. Reviewed By:

Rheanna Kautzman

Environmental Scientist

Division of Air Quality

RK:saj

10

march 22, 2019. direct comments, in writing, to the north ... · ignition internal combustion...

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