the state of new hampshire department of …solar turbines model: centaur 40 serial no. 3826c52 1997...

The State of New Hampshire

DEPARTMENT OF ENVIRONMENTAL SERVICES ____________

Robert R. Scott, Commissioner

DES Web site: www.des.nh.gov P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095

Telephone: (603) 271-1370 Fax: (603) 271-1381 TDD Access: Relay NH 1-800-735-2964

August 12, 2019

Steven J. Poggi New England/Upper New York Market Area Director of Disposal Operations Waste Management of New Hampshire, Inc. 4 Liberty Ln Hampton, NH 03842 RE: On-Site Full Compliance Evaluation Report Dear Mr. Poggi:

The New Hampshire Department of Environmental Services, Air Resources Division (NHDES) has completed a Full Compliance Evaluation of Waste Management of New Hampshire, Inc.’s Turnkey Recycling and Environmental Enterprise located in Rochester, NH. The purpose of the evaluation was to determine compliance with its Title V Operating Permit TV-0062, Temporary Permit TP-0205, Temporary Permit TP-0239, NOx RACT Order ARD-01-001 and the N.H. Code of Admin. Rules, Env-A 100 et seq. The compliance evaluation included an on-site inspection completed on July 16 and 17, 2019. This is a copy of the On-Site Full Compliance Evaluation Report for your review and records.

Please note that this Full Compliance Evaluation pertains only to N.H. Code Admin. Rules,

Env-A 100 et seq. as they relate to your air permit. Any compliance determination made with respect to the air rules does not in any way imply compliance with any other applicable environmental rules or laws.

NHDES identified deficiencies during this compliance evaluation, as detailed in this report. If you have any questions, please contact Michael Camacho at (603) 271-6797 or email at

[email protected]. Sincerely,

Michael Camacho Compliance Assessment Engineer Air Resources Division cc: City Manager, City of Rochester, City Hall, 31 Wakefield St, Rochester, NH 03867

William Howard, District Engineer, WMNH-TREE, 30 Rochester Neck Rd, Gonic, NH 03839

http://www.des.nh.gov/

mailto:[email protected]

WMNH – Turnkey Recycling and Environmental Enterprise Inspection Date: July 16-17, 2019 On-Site Full Compliance Evaluation Report Date: August 12, 2019

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Abbreviations and Acronyms AAL Ambient Air Limit acf actual cubic foot ags above ground surface ASTM American Society of Testing and Materials Btu British thermal units CAS Chemical Abstracts Service cfm cubic feet per minute CFR Code of Federal Regulations CO Carbon Monoxide CO2e Carbon Dioxide equivalents DER Discrete Emission Reduction Env-A New Hampshire Code of Administrative Rules – Air Resources Division ERC Emission Reduction Credit ft foot or feet ft3 cubic feet gal gallon HAP Hazardous Air Pollutant hp horsepower hr hour kW kilowatt lb pound LFG Landfill gas LPG Liquefied Petroleum Gas MM million MSDS Material Safety Data Sheet MW megawatt NAAQS National Ambient Air Quality Standard NG Natural Gas NHDES New Hampshire Department of Environmental Services NOx Oxides of Nitrogen NSPS New Source Performance Standard PM10 Particulate Matter < 10 microns ppm parts per million psi pounds per square inch RACT Reasonably Available Control Technology RICE Reciprocating Internal Combustion Engine RSA Revised Statues Annotated RTAP Regulated Toxic Air Pollutant scf standard cubic foot SO2 Sulfur Dioxide tpy tons per consecutive 12-month period TSP Total Suspended Particulate


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ULSD Ultra Low Sulfur Diesel USEPA United States Environmental Protection Agency VOC Volatile Organic Compound


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I. Facility Description NHDES conducted an On-Site Full Compliance Evaluation of Waste Management of New Hampshire, Inc. Turnkey Recycling and Environmental Enterprise (TREE) on July 16 and 17, 2019 and the results are presented herein. The compliance evaluation covers the period calendar year 2016 to July 17, 2019. TREE is an integrated solid waste management facility located on approximately 1,248 acres off Rochester Neck Road, in Rochester, NH. TREE has three landfills: TLR-I and TLR-II are capped landfills, which closed in 1992 and 1997, respectively; TLR-III, an active landfill, commenced operation in December 1995 and continues as an active landfill. TREE collects landfill gas (LFG) from all three landfills and treats and/or combusts the collected gas in several devices – including engines, turbines, and flares. The engines and turbines also provide electric generation. A portion of the untreated LFG that is collected is supplied to the University of New Hampshire (UNH), where it is treated and sent via pipeline to the UNH Campus. UNH operates under its own permits, which were not reviewed as part of this inspection report. TREE is required to obtain a Title V permit because it is a major source for NOx, CO, and SO2. TREE is also required to obtain a Title V permit pursuant to 40 CFR 60 Subpart WWW.

The facility currently operates under Title V Permit TV-0062, Temporary Permit TP-0205, Temporary Permit TP-0239 and NOx RACT Order ARD-01-001.

Facility name and address

Waste Management of New Hampshire, Inc. Turnkey Recycling and Environmental Enterprise 90 Rochester Neck Rd Rochester, New Hampshire 03867

County Strafford

Telephone (603) 330-2197

AFS# 3301700003

Source Type Title V, Mega Site

Inspection Date/Time July 16, 2019, 9:30 am July 17, 2019, 9:30 am

Inspection Type On-Site Full Compliance Evaluation

Weather

July 16: Mid 80soF., 5 -10 mph wind from south west, partially cloudy July 17: Mid 80soF., 5-10 mph wind from south west, humid, cloudy

Evaluation Period 2016 to July 17, 2019

Inspected by Michael Camacho, NHDES Compliance Assessment Engineer Sheila Rydel, NHDES NSR Program Manager

Source Contact(s) William Howard, District Engineer

Last Inspection September 1, 2016


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Last Inspection Results:

NHDES found no deficiencies during this compliance evaluation.

Permitting / Application Timeline

Permit TV-0062 Issued January 3, 2012

Expired January 31, 2017 (application shield applies)

Minor Modification September 11, 2012

Minor Modification August 22, 2013

Renewal Application Application #16-0124 Submitted July 29, 2016

Temporary Permit TP-0239 Issued June 6, 2019

Expires December 31, 2020

Temporary Permit TP-0205 Issued May 23, 2017

Expired November 30, 2018 (application shield applies)

TREE submitted application #16-0124 on July 29, 2016 for the renewal of Title V Operating Permit TV-0062, which expired on January 31, 2017. Since the application was received at least six months prior to the expiration date, application shield provisions apply. NHDES sent TREE a completeness letter on September 23, 2016. Temporary Permit TP-0239 was issued after TREE performed emission testing for formaldehyde from its four landfill gas-fired reciprocating engines in November, 2017. Based on the results, TREE prepared an Alternative Compliance Demonstration pursuant to Env-A 1405.06 for formaldehyde emissions based on operating only two landfill gas-fired engines at the same time. The Alternative Compliance Demonstration was approved on November 2, 2018. Operating not more than two engines at one time limits facility-wide HAP emissions to less than the major source thresholds of 10 tpy for any individual HAP and 25 tpy for all HAPs combined. The requirements of TP-0239 will be incorporated into the TV-0062 permit renewal. Temporary Permit TP-0205 was issued to install a new emergency generator (EU30) at the wastewater treatment plant. The requirements of TP-0205 will be incorporated into the TV-0062 permit renewal. The on-site inspection included an opening meeting to discuss the purpose of the inspection as well as the rules pertaining to claims of confidentiality and facility safety concerns. TREE agreed to the inspection and authorized access to the facility. Material provided and operations conducted by TREE at the time of the inspection were not claimed as confidential.

II. Emission Unit Identification and Facility Wide Emissions Table 1 below, taken from Permit TV-0062, lists the permitted emission units as verified during the evaluation.


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Table 1 – Emission Unit Identification

Emission Unit ID

Device or Area Source Name/

Manufacturer/ Model/

Serial Number Year Installed

Maximum Permitted Capacity/

Permitted Fuel Type(s)/ Nominal Heat Input or

Fuel Rate

EU02 Flare No. 2 (Utility Flare)

LFG Specialties’ Inc. Model CF1020I8 Serial No. 1298

1995 1,500 scfm Landfill Gas 49.5 MMBtu/hr

EU03 Reciprocating Engine No. 1 Caterpillar Model 3516 Serial No. 3RC00348

1992 10.0 MMBtu/hr Treated Landfill Gas 303 scfm

EU04 Reciprocating Engine No. 2 Caterpillar Model 3516 Serial No. 4EK01362






EU07 Emergency Generator at Leachate Treatment Plant

Caterpillar Model 3406TA Serial No. 2WB04342

1992

2.79 MMBtu/hr (275 kW) Diesel Fuel Oil 20.4 gal/hr

EU08 Turbine No. 1 Solar Turbines Model: Centaur 40 Serial No. 3826C52

1997 50 MMBtu/hr Treated Landfill Gas 1,515 scfm

EU09 Turbine No. 2 Solar Turbines Model: Centaur 40 Serial No. 3000405

1997 50 MMBtu/hr Treated Landfill Gas 1,515 scfm

EU15 Flare No. 3 (Ultra Low Emissions)

John Zink Company Model No. ZULE130X40LF Serial No. 938953

2002 3900 scfm Landfill Gas 128.7 MMBtu/hr

EU19 Flare No. 5 (Utility Flare)

LFG Specialties, Inc. Model PCF1434I12 Serial No. 1822

2006 3,200 scfm Landfill Gas 105.6 MMBtu/hr

EU21 Paint Spray Booth Global Finishing Solutions Model No. CDN-1615-NDT-64-S Serial No. 71189

2010 54 feet long by 16 feet wide by 15 feet high

EU22 Landfill TLR-I -- 1979 2.52 Million Mg (closed)

EU23 Landfill TLR-II -- 1990 3.48 Million Mg (closed)

EU24 Landfill TLR-III -- 1995 34.5 Million Mg (Active)


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Table 1 – Emission Unit Identification

Emission Unit ID

Device or Area Source Name/

Manufacturer/ Model/

Serial Number Year Installed

Maximum Permitted Capacity/

Permitted Fuel Type(s)/ Nominal Heat Input or

Fuel Rate

EU25 Leachate Concentrator This device is no longer in operation.

Bionomic Industries Model No. 20 Serial No. 10852

2011 20,000 Gallons/Day

EU26 Autoclave Steam Boiler This device has been removed from the facility.

Seller-Ygnis Model SY-225-S Serial No. 104350

2011 100 Gallons/Hr Propane 9.416 MMBtu/Hr

EU27

Healthcare Waste Facility Heating Boiler Now Rochester Hauling Company Maintenance Garage Boiler

Cleaver Brooks Model No. CFC-700-2500-125HW Serial No. 16010250110199

2011 27 gallons/Hr Propane 2.5 MMBtu/Hr

EU28 Leachate Treatment Plant Boiler

Hurst Boiler & Welding Company, Inc. Model 45-X-207.5-100W-1 Serial No. FB923-100W-1

2011

8.125 MMBtu/hr Treated Landfill Gas (or LPG)

255 scfm (89 gal/hr) Currently only combusts NG

EU29 Generator (TLR-III Scalehouse)

Generac Model 5518

2009 < 25 HP LPG

Table 1 below, taken from Permit TP-0205, lists the permitted emission units as verified during the evaluation.

Table 1 - Emission Unit Identification

Emission Unit ID

Device Identification

Manufacturer Model Number Serial

Number

Installation Date

Maximum Design Capacity and Permitted Fuel Type(s)

EU30

900 bHP (600 ekW)

Wastewater Treatment Plant

Emergency Generator

Caterpillar Model # C18

Serial # FST01565 2017

5.85 MMBtu/hr (40 CFR Part 60, Subpart IIII, USEPA Certified Tier 2), ULSD- equivalent to 42.7 gal/hr

NHDES observed the devices EU02 through EU09, EU15, EU19, EU21 through EU24 and EU27 through EU30, identified in the tables above. EU25 and EU26 has been decommissioned, and are no longer in operation. It has been determined that EU29 is an insignificant activity, and will be deemed as such in the permit renewal. TREE has made no changes to the operating permitted devices. The devices in operation during the inspection were EU04, EU08 and EU09. EU22 and EU23 are the closed landfills. EU24 is the active landfill. The remaining devices were not in operation at the time of inspection.


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NHDES observed the hour meters on the emergency generators. The hour meter readings listed in the table below are from the non-resettable hour meters on each generator which shows total hours on the device from initial start-up. TREE presented documentation demonstrating that each emergency generator operated less than 100 hours per year.

Unit Hour Meter Reading

– 2016 evaluation (hours)

Hour Meter Reading -- 2019 evaluation

(hours) Difference

Emergency Generator at Leachate Treatment Plant (EU07)

1531 1537.3 6.3

Emergency Generator at the Scale House (EU29)

101.3 140.5 39.2

Wastewater Treatment Plant Emergency Generator (EU30)

--- 102.8 ---

Insignificant Activities The table below lists the insignificant activities identified by the facility and confirmed by NHDES. The table was developed from a 12-month operating hours table received by NHDES during the on-site inspection and a list of insignificant activities from the renewal application filed on July 29, 2016.

Insignificant Activities

Description Fuel Type Comments

MISCELLANEOUS COMBUSTION DEVICES

Landfill Maintenance Garage

Space Heater Propane


Pressure Washer Propane

Hot Air Furnace No. 2 Oil


Used Oil Heater Waste Oil

Old Hauling Company Maintenance Garage




Hauling Company Old Container Repair Shop Devices Removed


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LFG Maintenance Shop


Space Heater Propane Removed


Material Recovery Facility

Hot Water Boiler Propane Removed


HAF Propane Removed

Hot Water Boiler Propane

Portable Electric Generator

Diesel Will need to be permitted. See Section X.

Other Findings for more detail.

Landfill Office

Hot Water Boiler No. 2 Oil

Landfill Storage Garage


Landfill Construction Offices


Classroom/Classroom Garage

Hot Air Furnace Propane Removed


TLR-III Scale House

Hot Water Boiler No. 2 Oil

Administration Building (Visitor’s Center)




RHD New Can Shop

MTO Space Heater Propane

ULO Space Heater Propane Removed

N Space Heater Propane

S Space Heater Propane

E Space Heater Propane


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RHD New Can Shop-PSB


New HC Maintenance Garage


BULK STORAGE TANKS

Location Material Capacity (gal)

Hauling Company Maintenance Garage Gasoline Tank 500

Diesel Fuel 11,000

Landfill Maintenance Garage

Virgin Engine Oil

500

Hydraulic Oil 300

Transmission Fluid

300

Kerosene 275

Used Oil for Recycle

500

Gear Oil 275

Gas Recovery I

Virgin Engine Oil

500

Virgin Engine Oil

500

Used Oil for Recycle

2000

TLR-III Scalehouse Heating Oil (Portable)

275

Leachate Treatment Facility Diesel Fuel 500

TLR-III Diesel Fuel 500

Homeless Shelter Heating Oil 275

Landfill Gas Recovery II LFG

Condensate 550

MISCELLANEOUS SOURCES

Location Description Basis

Landfill Maintenance Garage Degreaser Zep 143


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Location Description Basis

Hauling Company Maintenance Garage Degreaser Ozzy Juice SW-4 (Non-

VOC degreaser)

Gas Recovery I Degreaser Armakleen MPC (Non-

VOC degreaser)

Gas Recovery II Degreaser Armakleen MPC (Non-

VOC degreaser)

Gas Recovery I Engine

crankcase vents

Each engine less than 330 lbs. See Appendix B of 7/29/16 renewal

application.

Reverse Osmosis Treatment Building Sulfuric Acid Storage Tank

Emissions less than 1 lb/yr

The table below lists the facility’s reported annual emissions for the review period.

Facility Reported Annual Emissions (tpy)

PM10 SO2 NOx CO Non-

Methane VOC

Non-VOC HAPs/

RTAPs

Permitted Limits — <250 --- <250 <49.9 Individual: <10

Total: <25

2018 2.812 33.244 45.875 54.608 15.572 16.264

2017 2.556 43.701 38.341 49.529 13.292 21.308

2016 2.559 43.956 40.586 49.297 11.127 10.837

III. Control Equipment

Table 3 below, taken from Permit TV-0062, lists the required control equipment for the facility's devices, as verified during the evaluation.

Table 3 - Pollution Control Equipment Identification

Pollution Control Equipment ID

Description Purpose Emission Unit Controlled

PCE01 Flare No. 2 (EU02) For control of NMOC, HAPs, and RTAPs

EU22, EU23, and EU24


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Table 3 - Pollution Control Equipment Identification

Pollution Control Equipment ID

Description Purpose Emission Unit Controlled





PCE04 Engine Plant LFG Treatment System

For control of NMOC and HAPs


PCE05 Reciprocating Engine No. 1 (EU03)

For control of RTAPs EU22, EU23, and EU24







PCE09 Turbine No. 1 (EU08) For control of RTAPs EU22, EU23, and EU24

PCE10 Turbine No. 2 (EU09) For control of RTAPs EU22, EU23, and EU24

PCE11* Boiler at Leachate Treatment Plant (EU28)


PCE12 Turbine Plant LFG Treatment System

For control of NMOC and HAPs


*The Leachate Treatment Plant Boiler (PCE11)/(EU28) converted from combusting LPG/LFG to natural gas in October 2016. No physical alterations to the boiler were required. Due to the fact that it no longer combusts LFG, it is no longer designated as PCE.

IV. Stack Criteria


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Table 2 below, taken from Permit TV-0062, lists the permitted stack requirements for the facility. During the inspection, NHDES observed that the stacks were vertical and unobstructed with no modifications noted by the facility.

Table 2 - Stack Criteria

Stack # Emission Unit # Minimum Height

(feet above ground surface)

Maximum Exit Diameter (feet)

Stack 2 EU02 24 0.83

Stack 3 EU03 40 0.67*

Stack 4 EU04 40 0.67*

Stack 5 EU05 40 0.67*

Stack 6 EU06 40 0.67*

Stack 7 EU07 15 0.5

Stack 8 EU08 49 4.0

Stack 9 EU09 49 4.0

Stack 10 EU28 41.6 1.83

Stack 11 EU15 40 13

Stack 12 EU19 35.0 1.0

Stack 14 EU21 26.5 3.77

*The stack diameter of each LFG-fired engine has been corrected from 0.67 feet to 0.875 feet in the proposed permit renewal.

V. Compliance with Operating and Emission Limitations Permit Conditions Table 4 below, taken from Permit TV-0062, lists the State-only enforceable operation and emission limitations for the facility, and any deficiencies noted during the evaluation.


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Table 4 - State-only Enforceable Operational and Emission Limitations

Item #

Applicable Requirements Applicable

Emission Unit Regulatory Citation Compliant

1. 24-hour and Annual Ambient Air Limit

The emissions of any Regulated Toxic Air Pollutant (RTAP) shall not cause an exceedance of its associated 24-hour or annual Ambient Air Limit (AAL) as set forth in Env-A 1450.01, Table Containing the List Naming All Regulated Toxic Air Pollutants.

Facility-wide Env-A 1400

TP-0028

Yes

Finding: At NHDES request, formaldehyde emissions testing was performed on November 7-8, 2017. The results indicated that TREE exceeded formaldehyde emissions limits from its LFG-fired engines. NHDES issued TP-0239 to limit TREE engine operations to no more than two engines at any time, which keeps the facility below 24-hour Ambient Air Limits. TREE has maintained compliance with the limits of TP-0239 during this evaluation period. See Section IX. Permit Deviation Reporting Requirements for more detail.

2. Precautions to Prevent, Abate, and Control Fugitive Dust

The Owner or Operator shall take precautions at all times to prevent, abate, and control the emission of fugitive dust, including but not limited to such measures as wetting, covering, or vacuuming.

Facility-wide Env-A 1002.04

Yes

Finding: During the on-site inspection, NHDES observed a watering truck operating at the facility.

3. Revisions of the List of RTAPs

In accordance with RSA 125-I:5 IV, if the Division revises the list of RTAPs or their respective AALs or classifications under RSA 125-I:4, II and III, and as a result of such revision the Owner or Operator is required to obtain or modify the permit under the provisions of RSA 125-I or RSA 125-C, the Owner or Operator shall have 90 days following publication of notice of such final revision in the New Hampshire Rulemaking Register to file a complete application for such permit or permit modification.

Facility-wide RSA 125-I:5 IV

TP-0028

Yes

4. Operating Requirements for Permit Deviations

In the event of a permit deviation, the Owner or Operator shall investigate and take corrective actions immediately upon discovery of the permit deviation to restore the affected device, process, or air pollution equipment to within allowable permit levels.

Facility-wide Env-A 911.03(a)

Yes

5. Activities Exempt from Visible Emission Standards The average opacity shall be allowed to be in excess of those standards specified in Env-A 2002.02 for one period of 6 continuous minutes in any 60 minute period during startup, shutdown, or malfunction.

All combustion devices

Env-A 2002.04(c)

Yes

Finding: During the on-site inspection, visible emissions from devices in operation were less than five percent.

6. RTAP Operating Limitations

Emissions of RTAPs from TLR-I, TLR-II, and TLR-III and the Treatment System shall be controlled using the control devices as specified in Table 3 to maintain compliance


Env-A 1400 Not

Applicable


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Table 4 - State-only Enforceable Operational and Emission Limitations

Item #

Applicable Requirements Applicable

Emission Unit Regulatory Citation Compliant

with the associated 24-hour and annual AAL as set forth in Env-A 1450.01, Table Containing the List Naming All Regulated Toxic Air Pollutants.

Finding: Fugitive emissions from EU22, EU23, and EU24, preliminary treatment systems (PCE04 and PCE12) and flares (EU02, EU15 and EU19) are subject to 40 CFR 63 Subparts A, AAAA and 40 CFR 60 Subpart WWW and are therefore exempt from Env-A 1400. At the time TV-0062 was issued, this exemption did not exist. The proposed permit does not contain this item. All other devices at the facility that do not combust virgin fuels (i.e. engines and CTs) or otherwise emit RTAPs (e.g. spray painting, wastewater treatment) are subject to Env-A 1400.

Table 5 below, taken from Permit TV-0062, lists the Federally enforceable operation and emission limitations for the facility, and any deficiencies noted during the evaluation.

Table 5 – Federally Enforceable Operational and Emission Limitations

Item #

Applicable Requirement Applicable

Emission Unit Regulatory

Citation Compliant

1. The Facility shall comply with the National Ambient Air Quality Standards (NAAQS) and the applicable requirements of RSA 125-C:11 and Env-A 606.04.

Facility-wide RSA 125-C:11 & Env-A 606.04

TP-0065

Yes

2. Facility-wide Carbon Monoxide Emissions Cap

Combined total emissions of CO shall be less than 250 tons in any consecutive 12-month period.

Facility-wide Env-A 619 and

TP-0065

FP-T-0168

Yes

3. Facility-wide Sulfur Dioxide Emissions Limitation

Combined total emissions of SO2 shall be less than 250 tons in any consecutive 12-month period.

Facility-wide Env-A 619 and

TP-0065

FP-T-0168

Yes

4. VOC Limit

Facility-wide VOC emissions from non-fugitive sources shall be limited to 49.9 tons per any consecutive 12-month period.

Facility-wide Env-A 604.02(a)(1)

TP-0028 Yes


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Item #



Citation Compliant

5. Emission Limitations for Specific Devices

Emissions from individual devices shall not exceed the short-term emission limitations (hourly emission rates) listed below per Env-A 607.01(y). These limits are more stringent than either the NSPS or NOx RACT requirements for each respective device where applicable. The listed values were used in air dispersion modeling pursuant to Env-A 606 for the purpose of demonstrating compliance with NAAQS. No increase in these emission limitations shall be allowed unless:

1. An air quality impact analysis meeting the criteria of Env-A 606 has been performed;

2. The results of the analysis are deemed acceptable by the Department; 3. The changes do not exceed appropriate Federal NSPS, state standards or

RACT orders for the devices; and 4. The revised short-term emission limitations are incorporated into a

Temporary permit per Env-A 607.

Short-Term Emission Limitations (lb/hr)

Emission Unit #

Device Identification PM10 SO2 Regulatory

Citation

EU02 Flare No. 2 (Utility Flare) 12.2 FP-T-0168

EU03 Reciprocating Engine No. 1 2.46 TP-0065

PO-B-1821


PO-B-1822

EU05 Reciprocating Engine No. 3 2.46 TP-0065 PO-B-1823


PO-B-1824

EU08 Turbine No. 1 13.4 FP-T-0168

EU09 Turbine No. 2 13.4 FP-T-0168

EU15 Flare No. 3 (Ultra Low Emissions)

2.3 31.6 FP-T-0168

Env-A 607.01(y) TP-0065

Yes

Finding: The SO2 limitations assume the LFG Total Reduced Sulfur (TRS) concentration for EU02-EU06 is 800 ppm and 870 ppm for EU08 and EU09. During the evaluation period, the TRS concentration has not exceeded these concentrations. Therefore, NHDES determined that TREE complies with these limitations. EU15 did not operate this evaluation period.

6. Standard for Oxides of Nitrogen for Gas Turbines

No owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any stationary gas turbine, any gases which contain nitrogen oxides in excess of:

EU08 and EU09 40 CFR 60.332(a)(2) (Subpart GG)

PO-B-2010 PO-B-2001

Yes


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Item #



Citation Compliant

where:

STD = allowable ISO corrected (if required as given in §60.335(b)(1)) NOx emission concentration (percent by volume at 15 percent oxygen and on a dry basis),

Y = manufacturer's rated heat rate at manufacturer's rated peak load (kilojoules per watt hour), or actual measured heat rate based on lower heating value of fuel as measured at actual peak load for the facility. The value of Y shall not exceed 14.4 kilojoules per watt hour, and

F = NOX emission allowance (percent by volume) for fuel-bound nitrogen as defined in paragraph §60.332(a)(4).

7. NOx RACT for Gas Turbines

Emissions of Oxides of Nitrogen shall not exceed 55 parts per million by volume at 15% oxygen or 0.203 lb/MMBtu.

EU08 and EU09 Env-A 1306.03(b)(1)

(effective 10-31-10) Formerly

Env-A 1211.06(c)(2)

PO-B-2010 PO-B-2001

Yes

Finding: EU08 and EU09 NOx RACT stack testing occurred on November 7-8, 2017. Results from the stack test indicated NOx emissions were below permit limits.

8. Standard for Sulfur Dioxide for Gas Turbines

On and after the date on which the performance test required to be conducted by §60.8 is completed, every owner or operator subject to the provision of this subpart shall comply with one or the other of the following conditions:

a No owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any stationary gas turbine any gases which contain sulfur dioxide in excess of 0.015 percent by volume at 15 percent oxygen and on a dry basis; or

b No owner or operator subject to the provisions of this subpart shall burn in any stationary gas turbine any fuel which contains total sulfur in excess of 0.8 percent by weight (8000 ppmw).

EU08 and EU09 40 CFR 60.333 (Subpart GG)

Yes

Finding: LFG burned in EU08 and EU09 was below the limits of Item 8. b during this evaluation period.

9. NOx RACT for flares

Flares shall meet the NOx emission requirements of the NOx RACT Order ARD-01-001

EU02, EU15, EU19 and any open flare or

Env-A 1314 and Env-A 1316 Yes


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Item #



Citation Compliant

enclosed flare

10. Flare Operation

a. Non-assisted flares, shall combust gas with a net heating value of 7.45 MJ/scm (200 Btu/scf) or greater. The net heating value of the gas being combusted shall be determined by the methods specified in 40 CFR 60.18(f)(3); or

b. Flares shall be designed and operated with an exit velocity, as determined by the methods specified in 40 CFR 60.18(f)(4), that is less than 18.3 m/sec (60 ft/sec), except as provided in 40 CFR 60.18 (c)(4)(ii) and (c)(4)(iii). Pursuant to 40 CFR 60.18 (c)(4)(ii), Flares may be designed for and operated with an exit velocity, as determined by the methods specified in 40 CFR 60.18 (f)(4), that is equal to or greater than 18.3 m/sec (60 ft/sec) but less than 122 m/sec (400 ft/sec) if the net heating value of the gas being combusted is greater than 37.3 MJ/scm (1,000 Btu/scf). Pursuant to 40 CFR 60.18 (c)(4)(iii), Flares may be designed for and operated with an exit velocity, as determined by the methods specified in 40 CFR 60.18 (f)(4), that is less than the velocity, Vmax, as determined by the method specified in 40 CFR 60.18(f)(5), and less than 122 m/sec (400 ft/sec);

c. Pursuant to 40 CFR 60.18(f)(4), the actual exit velocity of Flare shall be determined by dividing the volumetric flow rate (in unit of standard temperature and pressure), as determined by Reference Methods 2, 2A, 2C, 2D as appropriate, by the unobstructed (free) cross sectional area of the flare tip;

d. The maximum permitted velocity, Vmax, for flares complying with 40 CFR 60.18 (c)(4)(iii) shall be determined by the following equation:

7.31

)8.28(max)(10

HTVLog

Vmax=Maximum permitted velocity, M/sec

HT=The net heating value as determined in 40 CFR 60.18 (f)(3)

e. Flares shall be operated with a flame present at all times when landfill gas is vented to them.

EU02, and EU19, and any

open flare burning

untreated landfill gas

40 CFR 60.18 (Subpart A)

TP-B-0525

Yes

11. Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985

EU15 and EU19 Env-A 2002.08 TP-B-0525 Yes


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Item #



Citation Compliant

The particulate matter emissions from fuel burning devices with a rating greater than 100 MMBtu installed on or after January 1, 1985 shall not exceed 0.15 lb/MMBtu.

TP-B-0482

Finding: Compliance with particulate emission standards can only be verified through stack testing. Stack testing for particulate matter has not been required for EU15 and EU19, to date. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, these devices are capable of meeting the particulate matter standard. EU15 did not operate during this evaluation period.

12. Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985

The particulate matter emissions from fuel burning devices with a rating less than 100 MMBtu/hr installed on or after January 1, 1985 shall not exceed 0.30 lb/MMBtu.

EU02-EU09, EU13, and

EU26

Env-A 2002.08(c)(1)

(Effective 4-23-05)

Formerly Env-A 1202.07

Yes

Finding: EU13 and EU26 have been removed from the facility. Compliance with particulate emission standards can only be verified through stack testing. Stack testing for particulate matter has not been required for EU02 through EU09, to date. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions these devices are capable of meeting the particulate matter standard.

13. Visible Emission Standard for Fuel Burning Devices Installed After May 13, 1970

The average opacity from fuel burning devices installed after May 13, 1970 shall not exceed 20 percent for any continuous 6-minute period.


EU26

Env-A 2002.02 TP-B-0525 TP-B-0482 PO-B-2010 PO-B-2001 PO-B-1927 PO-B-1821 PO-B-1822 PO-B-1823 PO-B-1824

Yes

Finding: EU13 and EU26 have been removed from the facility. During the on-site inspection, the opacity from EU04, EU08 and EU09 were in compliance with this requirement. The opacity from EU03, EU05 and EU07 could not be verified because the devices were not in operation.

14. Visible Emission Standards for Flares

Flares shall be operated with no visible emissions except for periods not to exceed a total of 5 minutes during any 2 consecutive hours as determined by Method 22 of appendix A of 40 CFR 60. Observation period is 2 hours.

EU02 and EU19 40 CFR 60.18(c)(1) (Subpart A)

TP-B-0525

Unknown

Finding: During the inspection, the opacity from EU02 and EU19 could not be verified because the devices were not in operation.

15. Visible Emission Standard for Process operations

The average opacity shall not exceed 20 percent for any continuous 6-minute period, except for one period of 6 continuous minutes in a 60-minute period during startup, shutdown or malfunction.

EU21 and EU25 Env-A 2103.02 TP-0028 TP-0065 Unknown

Finding: During the inspection, the opacity from EU21 could not be verified because the device was not in operation. EU25 has be disconnected and will be removed from the site.


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16. Operating Requirements for Pollution Control Equipment

The Owner or Operator shall operate and maintain the landfill gas flares in accordance with the recommended procedures and maintenance schedules of the respective equipment manufacturers.


Env-A 604.01

Yes

17. Applicability Criteria and Compliance Standards for Coating of Miscellaneous Metal Parts

a. Prior to January 1, 2016, the VOC content of coatings used in the surface coating of Miscellaneous Metal Parts and Products shall not exceed 3.5 lb/gal of coating as applied, excluding water and exempt compounds.

EU21 Env-A 1212.04(b)(1)

(Effective 6-1-11) Formerly Env-A 1204.15(c)(2)

TP-0028

Not Applicable

Finding: New VOC emission limitations came into effect on January 1, 2016, therefore, this requirement did not apply during this evaluation period.

b. On and after January 1, 2016, the VOC content of coatings as applied, excluding water and exempt compounds shall not exceed the VOC limits specified in Table 1212-1 in Env-A 1212.04.

EU21 Env-A 1212.04(a) (Effective 6-1-11)

Yes

c. Except as provided in d.) below, the Owner or Operator shall use one or more of the following coating application methods:

1. High volume-low pressure (HVLP) spray; 2. Electrostatic spray; 3. Zinc-arc spray; 4. Air-assisted airless spray; 5. Airless spray; 6. A flow coating technique; 7. Dip coat, including electrodeposition; or 8. Any other method with a transfer efficiency

equivalent to or better than that achieved by HVLP spraying.

d. The requirement in c.) above, shall not apply to: 1. A miscellaneous metal products coating

operation when: 2. Applying touchup or repair coatings; or 3. Applying textured finishes; 4. Airbrush operations using 5 gallons or less per

year of coating at a miscellaneous plastic coating operation; or

5. A pleasure craft surface coating operating when applying extreme high gloss coatings.

EU21 Env-A 1212.02 (Effective 6-1-11)

Yes

e. Work Practice Standards for Miscellaneous Metal and Plastic Parts and Products Coating for Waste Materials

EU21 Env-A 1212.03(a) (Effective 6-1-11) Yes


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The owner of a miscellaneous metal and plastic parts and product coating operation shall control VOC emissions from VOC-containing coatings, thinners, and coatings-related waste materials by using the following work practices:

1. Storing all VOC-containing coatings, thinners, and coatings-related waste materials in closed containers;

2. Keeping mixing and storage containers closed at all times except when depositing or removing VOC-containing coatings, thinners, and coatings-related waste materials;

3. Minimizing spills of VOC-containing coatings, thinners, and coatings-related waste materials; and

4. Conveying VOC-containing coatings, thinners, and coatings-related waste materials from one location to another in closed containers or pipes.

f. Work Practice Standards for Miscellaneous Metal and Plastic Parts and Products Coating for Cleaning Materials

The owner of a miscellaneous metal and plastic parts and product coating operation shall control VOC emissions from cleaning materials by using the following work practices:

1. Storing all VOC-containing cleaning materials and used shop towels in closed containers;

2. Keeping mixing and storage containers closed at all times except when depositing or removing VOC-containing materials;

3. Minimizing spills of VOC-containing cleaning materials;

4. Conveying VOC-containing cleaning materials from one location to another in closed containers or pipes; and

5. Minimizing VOC emissions from the cleaning of storage, mixing, and conveying equipment by ensuring that cleaning solvents are not atomized and all spent solvent is captured in closed containers.

EU21 Env-A 1212.03(b))

(Effective 6-1-11)

Not Applicable

Finding: VOC-containing cleaning materials are not used at this facility.


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18. Emergency Generators Each emergency generator shall only operate:

a. As a mechanical or electrical power source when the primary power source for the Facility has been lost during an emergency such as a power outage; or

b. During normal maintenance and testing as recommended by the manufacturer.

EU07 Env-A 1302.15 (Effective 10-31-

10) Formerly Env-A

1211.02(0) Yes

19. Emergency RICE Operating Requirements (manufactured prior to June 12, 2006):

Each RICE shall be operated as follows beginning May 3, 2013 for EU07:

a) Change oil and filter every 500 hours or annually, whichever comes first.

b) In lieu of “a” above, sources have the option to change the oil and filter in accordance with an Oil Analysis Program prepared and implemented as specified in 40

CFR 63.6625(i);

c) Inspect air cleaner every 1,000 hours or annually, whichever comes first and replace filter as necessary;

d) Inspect hoses and belts every 500 hours or annually, whichever comes first and replace as necessary;

e) Minimize the RICE's time spent at idle and minimize the RICE's startup time at startup to a period needed for appropriate and safe loading of the RICE, not to exceed 30 minutes; and

f) Operate and maintain the RICE according to the manufacturer's emission-related operation and maintenance instructions.

EU07 40 CFR 63.6603, Subpart ZZZZ

(Effective Date January 30,

2013)

Yes

20. Emergency Generators

If the stationary emergency RICE is not operated in accordance with the requirements in Table 5, items 18 or 30 the engine will not be considered an emergency RICE and must meet all requirements for non-emergency engines.

EU07 40 CFR 63.6640(f)

Subpart ZZZZ (Effective Date

January 30, 2013)

Noted

Finding: TREE operates EU07 in accordance with the requirements of Table 5, Items #18 and 30.

21. Maximum Sulfur Content Allowable in Liquid & Gaseous Fuels

a. No. 2 oil shall contain a maximum of 0.40% sulfur by weight.

b. Kerosene-1 oil shall contain a maximum of 0.04% sulfur by weight

Facility-wide Env-A 1604.01 &

Env-A 1605.01 Yes


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c. Gaseous fuels shall contain no more than 15 grains of sulfur per 100 cubic feet of gas at standard temperature and pressure.

Finding: As of February 1, 2019, No. 2 oil shall contain a maximum of 0.0015% sulfur by weight. The No. 2 fuel oil used on-site meets this requirement.

22. Inactive Disposal Sites for Asbestos

For any inactive waste disposal site that received deposits of asbestos-containing waste material, WMNH shall conduct the following:

a. Cover the asbestos containing waste material with at least 15 centimeters (6 inches) of compacted non-asbestos containing material, and grow and maintain a cover of vegetation on the area adequate to prevent exposure of the asbestos-containing waste material; or

b. Cover the asbestos-containing waste material with at least 60 centimeters (2 feet) of compacted non-asbestos containing material, and maintain it to prevent exposure of the asbestos containing waste; or

c. Unless a natural barrier adequately deters access by the general public, install and maintain warning signs and fencing. The warning signs shall be displayed at all entrances at intervals of 100 m (328 ft) or less along the property line or along the perimeter of the sections where asbestos-containing waste material was deposited and shall meet the specifications of 40 CFR 61.151 (b). The perimeter of the site shall be fenced in a manner adequate to deter access by the general public.

d. Notify EPA and DES in writing at least 45 days prior to excavating or otherwise disturbing any asbestos-containing waste material. The notification shall include the following:

1. Scheduled startup and completion dates,

2. The reason for disturbing the waste,

3. Procedures to be used to control emissions during the excavation, storage, transport, and ultimate disposal of the excavated asbestos-containing waste material,

4. Location of any temporary storage site and the final disposal site.

e. Within 60 days of a site becoming inactive, record a notation on the deed to the facility property, in accordance with state law, and on any other instrument that would normally be examined during a title search that the land has been used for the disposal


40 CFR 61.151 (Subpart M)

TP-0065

Yes


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of asbestos-containing materials; the survey plot and a record of location and quantity of asbestos-containing waste disposed has been filed with EPA; and the site is

subject to 40 CFR Part 61 Subpart M.

23. Active Disposal Sites for Asbestos

Active waste disposal site that receives asbestos containing material, WMNH shall meet the following requirements:

a. No visible emissions to the outside air; or

b. At the end of each operating day or at least once every 24-hour period while the site is in continuous operation, the asbestos-containing waste deposited during the operating day or within the previous 24-hour period shall be covered with at least 15 centimeters (6 inches) of compacted non-asbestos containing material or be covered with a resinous or petroleum-based dust suppression agent that effectively binds dust and controls wind erosion; or use an alternative control method that has received written approval from EPA.

c. Unless a natural barrier adequately deters access by the general public, either warning signs and fencing must be installed at all entrances and at intervals of 100 m (300 ft.) or less along the property line of the site or along the perimeter of the sections of the site where asbestos containing waste material is deposited. The warning signs must be posted in such a manner and location that a person can easily read the legend, and conform to the requirements established in 40 CFR 61.154 (b). The perimeter of the disposal site shall be fenced in a manner adequate to deter access by the general public.

EU24 40 CFR 61.154 (Subpart M)

TP-0065

Yes

Finding: During the on-site inspection, NHDES witnessed waste disposal at the asbestos containing material site. Waste deposited at this site was covered with non-asbestos containing material. No visible emissions to the outside air were present.

24. Accidental Release Program Requirements

The quantities of regulated chemicals stored at the facility are less than the applicable threshold quantities established in 40 CFR 68.130. The facility is subject to the Purpose and General Duty clause of the 1990 Clean Air Act, Section 112(r)(1). General Duty includes the following responsibilities:

a. Identify potential hazards which result from such releases using appropriate hazard assessment techniques;

b. Design and maintain a safe facility;

Facility-wide CAAA 112(r)(1) TP-0065

Yes


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c. Take steps necessary to prevent releases; and

d. Minimize the consequences of accidental releases that do occur.

Finding: TREE does not store quantities of regulated chemicals above the applicable threshold quantities.

25. Device NOx Emission Limitation

Total NOx emissions from Engines 1-4, Turbines 1-2, and Flare 2 shall not exceed 107.44 tons per consecutive 12 month period.

EU02, EU03-EU06, EU08,

and EU09

Env-A 618 PO-B-2010 PO-B-2010 PO-B-1927 PO-B-1821

Yes


Total NOx emissions from Flare 5 shall not exceed 17.8 tons per consecutive 12 month period.

EU19 Env-A 618 TP-B-0525 Yes


NOx Emissions from Flare 3 shall not exceed 12.6 tons per consecutive 12-month period.

EU15 Env-A 618 TP-B-0482 Yes

Finding: EU15 has not operated since 2009.

28. Engine NOx Emission RACT

Emissions of NOx from these devices shall not exceed 2.5 grams per brake horsepower hour as specified in Env-A 1300.

EU03-EU06 Env-A 1307.02(b)(1)

(Effective 10-31-2010)

Formerly Env-A 1211.07(c)(2)(a)

PO-B-1821 PO-B-1822 PO-B-1823 PO-B-1824

Yes

Finding: On November 7-9, 2017, emissions testing was conducted on each engine and the results demonstrated that each engine is in compliance with the NOx emission limit of 2.5 grams per brake horsepower hour or less.

29. Engine Operating Conditions

a. The devices shall be operated at maximum load conditions, or at load conditions established through the procedure outlined in c. below at all times except for periods of startup, shutdown, or malfunction;

b. For the purposes of this Permit, maximum load conditions shall be defined as the range of power output starting at 720 Kilowatts and ending at 880 Kilowatts; and

c. Operating load conditions for this device other than those listed in a. above may be allowed by the Division provided that the owner or operator demonstrates through a division approved performance test that all applicable emission limitations are met at the alternative operating load conditions. All performance

EU03-EU06 Env-A 607.01(y) PO-B-1821 PO-B-1822 PO-B-1823 PO-B-1824

Yes


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testing shall be conducted in accordance with Division Rules and policy.

30. Emergency RICE (Stationary RICE) manufactured prior to June 12, 2006:

EU07 shall be limited to 500 hours of operation during any consecutive 12-month period.

EU07 shall each be limited to 100 hours per year of operation for maintenance checks and readiness testing.

Beginning May 3, 2013, EU07 shall be limited to the following:

a. Emergency stationary RICE may be operated for maintenance checks and readiness testing, Table 5, Item per 18(b). These activities are limited to 100 hours per year.

b. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year.

EU07 40 CFR 63.6604, 63.6640(f)(2)(ii)

& (iii), 63.6640(f)(4)(ii),

63.6650(h) (Subpart ZZZZ)

&

Env-A 1301.02(j)(1)

Yes

31. SI-RICE Operating Requirements

Each Engine shall be operated as follows after May 3, 2013: a. Change oil and filter every 1,440 hours of operation or

annually, whichever comes first; b. Inspect spark plugs every 1,440 hours of operation or

annually, whichever comes first and replace as necessary;

c. Inspect hoses and belts every 1,440 hours of operation or annually, whichever comes first and replace as necessary:

d. Minimize idle time during startup and minimize startup time to a period needed for appropriate and safe loading, not to exceed 30 minutes; and

e. Operate and maintain the engine according to the manufacturer's emission-related operation and maintenance instructions.

EU03-EU06 40 CFR 63.6603, (Subpart ZZZZ)

Yes

32. Compliance to Municipal Solid Waste Landfill NESHAP(MSWLF NESHAP)

The Facility shall comply with the applicable Provisions of 40 CFR 63 Subpart AAAA.

EU22, EU23, and EU24 and

devices used to comply with 40 CFR 60 Subpart WWW and 40

40 CFR 63 (Subpart AAAA)

TP-B-0525 TP-0065

Yes


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CFR 63 Subpart AAAA

33. Compliance to Municipal Solid Waste Landfill NSPS (MSWLF NSPS)

The Facility shall comply with the applicable Provisions of 40 CFR 60 Subpart WWW.



CFR 63 Subpart AAAA

40 CFR 60 (Subpart WWW)

TP-0065

Yes

34. Compliance to Municipal Solid Waste Landfill NSPS

Each owner or operator of an MSW landfill having a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters, shall either comply with these requirements or calculate an NMOC emission rate for the landfill using the procedures specified in 40 CFR 60.754. The NMOC emission rate shall be recalculated annually. The owner or operator of an MSW landfill subject to this subpart with a design capacity greater than or equal to 2.5 million megagrams and 2.5 million cubic meters is subject to part 70 or 71 permitting requirements. If the calculated NMOC emission rate is equal to or greater than 50 megagrams per year, the owner or operator shall submit a collection and control system (GCCS) Design Plan prepared by a professional engineer to the USEPA Administrator and the Department within 1 year. All proposed changes to the plan shall be submitted to the Department and the USEPA Administrator in writing. Changes shall not be implemented without the Department’s or USEPA Administrator’s approval.

a. The collection and control system as described in the plan shall meet the design requirements of section §60.752(b)(2)(ii);

b. The collection and control system design plan shall include any alternatives to the operational standards, test methods, procedures, compliance measures, monitoring, recordkeeping or reporting provisions of §§60.753 through 60.758 proposed by the owner or operator;

c. The collection and control system design plan shall either conform with specifications for active collection systems in §60.759 or include a demonstration to the USEPA Administrator's or the Department's satisfaction of the sufficiency of the alternative provisions to §60.759; and



CFR 63 Subpart AAAA

40 CFR 60.752(b)(2)

(Subpart WWW)

TP-0065

Yes


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d. The USEPA Administrator or the Department shall review the information submitted under paragraphs a., b., and c. of this section and either approve it, disapprove it, or request that additional information be submitted. Because of the many site-specific factors involved with landfill gas system design, alternative systems may be necessary. A wide variety of system designs are possible, such as vertical wells, combination horizontal and vertical collection systems, or horizontal trenches only, leachate collection components, and passive systems.

Finding: In a letter dated October 8, 2018, NHDES approved the most recent changes to the GCCS Design Plan.

35. Landfill Gas Collection System Requirements

The owner or operator shall install a collection and control system that captures the gas generated within the landfill as required by a. or b. and §60.752(b)(2)(iii) within 30 months after the first annual report in which the emission rate equals or exceeds 50 megagrams per year, unless Tier 2 or Tier 3 sampling demonstrates that the emission rate is less than 50 megagrams per year, as specified in §60.757(c)(1) or (2).

a. An active collection system shall:

1. Be designed to handle the maximum expected gas flow rate from the entire area of the landfill that warrants control over the intended use period of the gas control or treatment system equipment;

2. Collect gas from each area, cell, or group of cells in the landfill in which the initial solid waste has been placed for a period of:

i. 5 years or more if active; or

ii. 2 years or more if closed or at final grade.

3. Collect gas at a sufficient extraction rate;

4. Be designed to minimize off-site migration of subsurface gas.

b. A passive collection system shall:

1. Comply with the provisions specified in paragraphs a.1, a.2, and a.4 of this section.

2. Be installed with liners on the bottom and all sides in all areas in which gas is to be collected. The liners shall be installed as required under §258.40.



CFR 63 Subpart AAAA

40 CFR 60.752(b)(2)(ii)

(Subpart WWW)

Yes

Finding: TREE has installed an active LFG collection system in TLR-I, TLR-II, and TLR-III.

36. Landfill Gas Control System Requirements EU22, EU23, and EU24,

EU02/PCE01, EU15/PCE02,

40 CFR 60.752(b)(2)(iii) (Subpart WWW)

Yes


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The owner or operator shall route all the collected gas to a control system that complies with the requirements in either paragraph a, b, or c of this section.

a. An open flare designed and operated in accordance with §60.18 except as noted in §60.754(e);

b. A control system designed and operated to reduce NMOC by 98 weight-percent, or, when an enclosed combustion device is used for control, to either reduce NMOC by 98 weight percent or reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen. The reduction efficiency or parts per million by volume shall be established by an initial performance test to be completed no later than 180 days after the initial startup of the approved control system using the test methods specified in §60.754(d). 1. If a boiler or process heater is used as the control

device, the landfill gas stream shall be introduced into the flame zone.

2. The control device shall be operated within the parameter ranges established during the initial or most recent performance test. The operating parameters to be monitored are specified in §60.756;

c. Route the collected gas to a treatment system that processes the collected gas for subsequent sale or use. All emissions from any atmospheric vent from the gas treatment system shall be subject to the requirements of paragraph a or b above.

EU19/PCE03, PCE04 and


CFR 63 Subpart AAAA

37 Operation of the Landfill Gas Collection and Control System

Each owner or operator of an MSW landfill with a gas collection and control system used to comply with the provisions of §60.752(b)(2)(ii) of this subpart shall:

a. Operate the collection system such that gas is collected from each area, cell, or group of cells in the MSW landfill in which solid waste has been in place for: 1. 5 years or more if active; or 2. 2 years or more if closed or at final grade;

b. Operate the collection system with negative pressure at each wellhead except under the following conditions: 1. A fire or increased well temperature. The owner or

operator shall record instances when positive pressure occurs in efforts to avoid a fire. These records shall be submitted with the annual reports as provided in §60.757(f)(1);



CFR 63 Subpart AAAA

40 CFR 60.753 (Subpart WWW)

Yes


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2. Use of a geomembrane or synthetic cover. The owner or operator shall develop acceptable pressure limits in the design plan;

3. A decommissioned well. A well may experience a static positive pressure after shut down to accommodate for declining flows. All design changes shall be approved by the USEPA Administrator or the Department;

c. Operate each interior wellhead in the collection system with a landfill gas temperature less than 55 °C and with either a nitrogen level less than 20 percent or an oxygen level less than 5 percent. The owner or operator may establish a higher operating temperature, nitrogen, or oxygen value at a particular well. A higher operating value demonstration shall show supporting data that the elevated parameter does not cause fires or significantly inhibit anaerobic decomposition by killing methanogens. 1. The nitrogen level shall be determined using

Method 3C, unless an alternative test method is established as allowed by §60.752(b)(2)(i) of this subpart.

2. Unless an alternative test method is established as allowed by §60.752(b)(2)(i), the oxygen shall be determined by an oxygen meter using Method 3A or 3C except that: i. The span shall be set so that the regulatory

limit is between 20 and 50 percent of the span; ii. A data recorder is not required; Iii Only two calibration gases are required, a zero

and span, and ambient air may be used as the span;

iv. A calibration error check is not required; v. The allowable sample bias, zero drift, and

calibration drift are ±10 percent. d. Operate the collection system so that the methane

concentration is less than 500 parts per million above background at the surface of the landfill. To determine if this level is exceeded, the owner or operator shall conduct surface testing around the perimeter of the collection area and along a pattern that traverses the landfill at 30 meter intervals and where visual observations indicate elevated concentrations of landfill gas, such as distressed vegetation and cracks or seeps in the cover. The owner or operator may establish an alternative traversing pattern that ensures equivalent coverage. A surface monitoring design plan shall be developed that includes a topographical map with the monitoring route and the rationale for any site-specific


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deviations from the 30 meter intervals. Areas with steep slopes or other dangerous areas may be excluded from the surface testing.

e. Operate the system such that all collected gases are vented to a control system designed and operated in compliance with §60.752(b)(2)(iii). In the event the collection or control system is inoperable, the gas mover system shall be shut down and all valves in the collection and control system contributing to venting of the gas to the atmosphere shall be closed within 1 hour; and

f. Operate the control or treatment system at all times when the collected gas is routed to the system.

g. If monitoring demonstrates that the operational requirements in paragraphs b, c, or d of this section are not met, corrective action shall be taken as specified in §60.755(a)(3) through (5) or §60.755(c). If corrective actions are taken as specified in §60.755, the monitored exceedance is not a violation of the operational requirements in this section.

38. Specifications for Collection Systems for Controlling Landfill Gas

Each owner or operator seeking to comply with §60.752(b)(2)(i) shall site active collection wells, horizontal collectors, surface collectors, or other extraction devices at a sufficient density throughout all gas producing areas using the following procedures unless alternative procedures have been approved by the USEPA Administrator or the Department as provided in §60.752(b)(2)(i)(C) and (D):

a. The collection devices within the interior and along the perimeter areas shall be certified to achieve comprehensive control of surface gas emissions by a professional engineer. The following issues shall be addressed in the design: depths of refuse, refuse gas generation rates and flow characteristics, cover properties, gas system expandability, leachate and condensate management, accessibility, compatibility with filling operations, integration with closure end use, air intrusion control, corrosion resistance, fill settlement, and resistance to the refuse decomposition heat.

b. The sufficient density of gas collection devices determined in a. of this section shall address landfill gas migration issues and augmentation of the collection system through the use of active or passive systems at the landfill perimeter or exterior.



CFR 63 Subpart AAAA

40 CFR 60.759(a) (Subpart WWW)

Yes


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c. The placement of gas collection devices determined in a. of this section shall control all gas producing areas, except as provided by c.1 and c.2 of this section. 1. Any segregated area of asbestos or nondegradable

material may be excluded from collection if documented as provided under §60.758(d). The documentation shall provide the nature, date of deposition, location and amount of asbestos or nondegradable material deposited in the area, and shall be provided to the USEPA Administrator and the Department upon request.

2. Any nonproductive area of the landfill may be excluded from control, provided that the total of all excluded areas can be shown to contribute less than 1 percent of the total amount of NMOC emissions from the landfill. The amount, location, and age of the material shall be documented and provided to the USEPA Administrator and the Department upon request. A separate NMOC emissions estimate shall be made for each section proposed for exclusion, and the sum of all such sections shall be compared to the NMOC emissions estimate for the entire landfill. Emissions from each section shall be computed using the following equation:

Qi= 2 k LoMi(e-kti) (CNMOC) (3.6 × 10−9)

where, Qi= NMOC emission rate from the ithsection, megagrams per year k = methane generation rate constant, year−1 Lo= methane generation potential, cubic meters per megagram solid waste Mi= mass of the degradable solid waste in the ithsection, megagram ti= age of the solid waste in the ithsection, years CNMOC= concentration of nonmethane organic

compounds, parts per million by volume 3.6×10−9= conversion factor

3. The values for k and CNMOC determined in field testing shall be used if field testing has been performed in determining the NMOC emission rate or the radii of influence (this distance from the well center to a point in the landfill where the pressure gradient applied by the blower or compressor approaches zero). If field testing has not been performed, the default values for k, LO and CNMOC


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provided in §60.754(a)(1) or the alternative values from §60.754(a)(5) shall be used. The mass of nondegradable solid waste contained within the given section may be subtracted from the total mass of the section when estimating emissions provided the nature, location, age, and amount of the nondegradable material is documented as provided in c.1.

39. Landfill Gas Collection System Requirements

Each owner or operator seeking to comply with §60.752(b)(2)(i)(A) shall construct the gas collection devices using the following equipment or procedures:

a. The landfill gas extraction components shall be constructed of polyvinyl chloride (PVC), high density polyethylene (HDPE) pipe, fiberglass, stainless steel, or other nonporous corrosion resistant material of suitable dimensions to: convey projected amounts of gases; withstand installation, static, and settlement forces; and withstand planned overburden or traffic loads. The collection system shall extend as necessary to comply with emission and migration standards. Collection devices such as wells and horizontal collectors shall be perforated to allow gas entry without head loss sufficient to impair performance across the intended extent of control. Perforations shall be situated with regard to the need to prevent excessive air infiltration.

b. Vertical wells shall be placed so as not to endanger underlying liners and shall address the occurrence of water within the landfill. Holes and trenches constructed for piped wells and horizontal collectors shall be of sufficient cross-section so as to allow for their proper construction and completion including, for example, centering of pipes and placement of gravel backfill. Collection devices shall be designed so as not to allow indirect short circuiting of air into the cover or refuse into the collection system or gas into the air. Any gravel used around pipe perforations should be of a dimension so as not to penetrate or block perforations.

c. Collection devices may be connected to the collection header pipes below or above the landfill surface. The connector assembly shall include a positive closing throttle valve, any necessary seals and couplings, access couplings and at least one sampling port. The collection devices shall be constructed of PVC, HDPE, fiberglass, stainless steel, or other nonporous material of suitable thickness.



CFR 63 Subpart AAAA

40 CFR 60.759(b) (Subpart WWW)

Yes


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40. Landfill Gas Collection System Specifications

Each owner or operator seeking to comply with §60.752(b)(2)(i)(A) shall convey the landfill gas to a control system in compliance with §60.752(b)(2)(iii) through the collection header pipe(s). The gas mover equipment shall be sized to handle the maximum gas generation flow rate expected over the intended use period of the gas moving equipment using the following procedures:

a. For existing collection systems, the flow data shall be used to project the maximum flow rate. If no flow data exists, the procedures in b. shall be used.

b. For new collection systems, the maximum flow rate shall be in accordance with §60.755(a)(1).



CFR 63 Subpart AAAA

40 CFR 60.759(c) (Subpart WWW)

Yes

41. Well Installation

For purposes of compliance with §60.753(a), each owner or operator of a controlled landfill shall place each well or design component as specified in the approved design plan as provided in §60.752(b)(2)(i). Each well shall be installed no later than 60 days after the date on which the initial solid waste has been in place for a period of:

a. 5 years or more if active; or b. 2 years or more if closed or at final grade.



Yes

42. The provisions of 40 CFR 60 Subpart WWW shall apply at all times, except during periods of start-up, shutdown, or malfunction, provided that the duration of start-up, shutdown, or malfunction shall not exceed 5 days for collection systems and shall not exceed 1 hour for treatment or control devices.



CFR 63 Subpart AAAA

40 CFR 60. 755(e)(1)

Yes

43. At all times, including periods of startup, shutdown, and malfunction, the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. During a period of startup, shutdown, or malfunction, this general duty to minimize emissions requires that the owner or operator reduce emissions from the affected source to the greatest extent which is consistent with safety and good air pollution control practices.



CFR 63 Subpart AAAA

40 CFR 63.6(e)

Yes

44. The owner or operator shall comply with the NOx RACT Order ARD-01-001 for Flares 2, 3, and 5, and any open and enclosed flare.

EU02, EU15, EU19 and any

open flare, ultra-low

Env-A 1314 (effective 10-31-

10) Yes


of 86


Item #



Citation Compliant

emission flare and enclosed

flare

45 a.) Purchase a certified engine in accordance with the requirements listed in 40 CFR Part 60 Subpart JJJJ.

b.) Operate and maintain the engine in accordance with manufacturer’s recommendations.

EU29 40 CFR 60.4231

&

40 CFR 60.4243(a)

Yes

46 NESHAP General Provision for all engines

a.) Maintain compliance with the emission limitations and operating limitations in this subpart that apply to the owner/operator at all times.

b.) At all times operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the owner/operator to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.

EU03 –EU06, &

EU07

40 CFR 63.6605

Subpart ZZZZ

(Effective Date January 30,

2013)

Yes

47 NSPS General Provisions

a.) At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source;

b.) For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in this part, nothing in this part shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate

EU29 40 CFR 60.11(g)

Yes


of 86


Item #



Citation Compliant

performance or compliance test or procedure had been performed.

Table 2 below, taken from Permit TP-0205, lists the operation and emission limitations for the facility, and any deficiencies noted during the evaluation.

Table 2 - Operating and Emission Limitations

Item # Requirement Applicable


Basis Compliant

1.

Maximum Sulfur Content Allowable in Liquid Fuels

The sulfur content of diesel fuel burned in the emergency generator engine subject to 40 CFR Part 60, Subpart IIII shall not exceed 15 ppm (0.0015 percent sulfur by weight).

EU30 40 CFR 60.4207

(Subpart IIII) Yes

2.

Visible Emission Standard for Fuel Burning Devices Installed After May 13, 1970

The average opacity from fuel burning devices installed after May 13, 1970 shall not exceed 20 percent for any continuous 6-minute period.

EU30 Env-A 2002.02 Unknown

Finding: EU30 was not in operation during the on-site inspection, therefore opacity could not be determined.

3.

Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985

The maximum allowable particulate matter emission rate for fuel burning devices installed on or after January 1, 1985 shall not exceed 0.30 lb/MMBtu.

EU30 Env-A 2003.03 Yes

Finding: Compliance with particulate emission standards can only be determined by stack testing, which has not been required for this device, to date. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, this device is capable of meeting the particulate matter standard.

4.

Operating Limitations for Emergency Generators

Each emergency generator shall be limited to 500 hours of total operation during any consecutive 12-month period and only under the operating scenarios limited in Table 2, Item 5.

EU30 Env-A

1301.02(j)(1)

Yes


of 86


Item # Requirement Applicable


Basis Compliant

5.

Limitations on Operating Scenarios for Emergency Engine

Each emergency engine shall only operate:

a. As a mechanical or electrical power source only when the primary power source for the facility is not available during an emergency; and

b. During the normal maintenance and testing.

No emergency engine shall operate as a load-shaving or peaking power production unit.

EU30 Env-A 101.671 Yes

6.

Additional Operating Limitations for New Emergency Engine

In addition to the operating hours limitation in Table 2, Item 4, the owner or operator of each emergency engine subject to 40 CFR Part 60, Subpart IIII shall operate the emergency engine for any combination of the purposes listed below for a maximum of 100 hours per calendar year:

a. Emergency engines may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine; and

b. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency engine beyond 100 hours per calendar year.

EU30

40 CFR 60.4211(f)

(Subpart IIII)

Yes

7.

New Source Performance Standards (NSPS) for Stationary Compression Ignition Internal Combustion Engines Subject to Regulations Under 40 CFR Part 60, Subpart IIII: Operational Requirements

The owner or operator of an emergency engine subject to the requirements of 40 CFR Part 60, Subpart IIII shall:

a. Purchase a certified emergency engine in accordance with the requirements listed in 40 CFR Part 60, Subpart IIII;

b. Install, configure, operate and maintain the engine according to the manufacturer's emission-related written instructions and operations and maintenance manual (O&M manual) or change only the emission-related settings in a way that is permitted by the manufacturer; and

c. Operate and maintain the engine to meet the emission standards over the entire life of the engine.

EU30

40 CFR 60.4205(b),

40 CFR 60.4211(a), &

40 CFR 60.4211(c)

(Subpart IIII)

Yes


of 86

Table 2 below, taken from Permit TP-0239, lists the operation and emission limitations for the facility, and any deficiencies noted during the evaluation.


Item # Applicable Requirements Applicable


Citation Compliant

1. Facility-Wide HAP Emission Limitation Facility-wide emissions of Hazardous Air Pollutants (HAPs, as defined in Section 112 of the 1990 Clean Air Act Amendments) shall be limited to less than 10 tpy for any individual HAP and 25 tpy for all HAPs combined.

Facility-Wide

Env-A 604.02(a)(1)

Yes


Emissions of RTAPs shall be controlled on a 24-hr and annual basis by limiting the operation of the landfill gas-fired engines to a maximum of two engines at the same time to maintain compliance with the Alternative Compliance Demonstration approved on November 2, 2018.

EU03 – EU06 Env-A 604.02(a)(2) and

Env-A 1400 (State-only

Enforceable Limit) Yes


Each engine shall not exceed a formaldehyde emission rate of 0.88 lb/hr to ensure compliance with the Alternative Compliance Demonstration approved on November 2, 2018.

EU03 – EU06 Env-A 1400 (State-only

Enforceable Limit) Future Requirement

Finding: On November 7-8, 2017, the engines were tested for formaldehyde, and the emission rate was found to be 0.88 lb/hr. This emission rate established the limitation above. The next compliance test is due to occur in the fourth quarter of 2020.

VI. Compliance with Monitoring and Testing Requirements

Table 6 below, taken from Permit TV-0062, lists the monitoring and testing requirements for the facility, and any deficiencies noted during the evaluation.

Table 6 - Monitoring/Testing Requirements

Item #

Parameter Method of Compliance Frequency of Method

Applicable Emission

Unit

Regulatory Citation

Compliant

1. Various pollutants

Stack Testing for Stationary Sources

When conditions warrant, the Division may require the Owner or Operator to conduct emission compliance testing in accordance with Department-approved methods.

As required Facility-wide RSA 125-C:6 XI

TP-0028 TP-B-0525 TP-B-0482 TP-0065

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

Finding: In a letter dated May 9, 2017, NHDES requested that TREE perform formaldehyde testing on EU03-EU06. Testing was performed on November 7-8, 2017.

2. NOx RACT Testing Engines

and Turbines

The Owner or Operator shall determine compliance with the NOx emission limits specified in Items 5, 7, and 28 of Table 5 of this Permit for Engines 1 through 4 and Gas Turbine 1 and 2 by conducting stack testing every three years. Compliance stack testing shall be conducted in accordance with Env-A 802. The following test methods shall be used as applicable:

a. Method 7, 7A, 7C, 7D or 7E as described in 40 CFR 60, Appendix A, to determine NOx concentrations in stack gases;

b. Method 10 as described in 40 CFR 60, Appendix A, to determine carbon monoxide concentrations in stack gases;

c. Methods 1 and 2, 2C, 2F, 2G, or 2H, 40 CFR 60, as described in Appendix A, to determine the exit flowrate of stack gases;

d. Method 3 or 3A, as described in 40 CFR 60, Appendix A, to determine carbon dioxide, oxygen, excess air and molecular weight (dry basis) of stack gases;

e. Method 4, as described in 40 CFR 60, Appendix A, to determine volume fraction of water vapor in stack gases; and

f. The Owner or Operator may use Method 20 as described in 40 CFR 60, Appendix A, in lieu of the above identified methods to determine NOx concentrations in stationary gas turbine stack gases.

Once every 3 years


EU09

PO-B-2010 PO-B-2001 PO-B-1821 PO-B-1822 PO-B-1823 PO-B-1824

Env-A 803 Effective

10-31-2010

Yes

Finding: On November 7-9, 2017, NOx RACT Testing was performed on EU03-EU06, EU08 and EU09. Results from the testing indicated compliance with this requirement.

3. NOx RACT Testing for Enclosed

Flares

The Owner or Operator shall determine compliance with the NOx emission limits specified in Items 5 and 9 of Table 5 of this Permit for Flare 3. Compliance stack

As specified in NOx RACT Order ARD-

01-001

EU15 Env-A 803 Effective

10-31-2010 Noted


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

testing shall be conducted in accordance with Env-A 803. The following test methods shall be used as applicable:

a. Method 7, 7A, 7C, 7D or 7E as described in 40 CFR 60, Appendix A, to determine NOx concentrations in stack gases;

b. Methods 1 and 2, 2C, 2F, 2G, or 2H, 40 CFR 60, as described in Appendix A, to determine the exit flowrate of stack gases;

c. Method 3 or 3A, as described in 40 CFR 60, Appendix A, to determine carbon dioxide, oxygen, excess air and molecular weight (dry basis) of stack gases;

d. Method 4, as described in 40 CFR 60, Appendix A, to determine volume fraction of water vapor in stack gases; and

Finding: TREE did not operate EU15 during the evaluation period. In accordance with the NOx RACT Order, TREE has 120 days after the date on which the flare is operated to conduct the required NOx RACT test.

4. NOx RACT Testing

Protocol

Compliance testing shall be planned and carried out in accordance with the following schedule: a. A pre-test protocol shall be

submitted to the Division at least 30 days prior to the commencement of testing;

b. The Owner or Operator and any contractor retained by the Owner or Operator to conduct the test shall meet with a Division representative at least 15 days prior to the test date to finalize the details of the testing; and

c. A test report shall be submitted to the Division within 60 days after the completion of testing.

Within 3 years of

the date of the most

recent compliance

test

EU03-EU06, EU08, EU09,

and EU15

Env-A 802 (Effective

10-31-2010)

PO-B-2010 PO-B-2001

Yes

5. VOC content of landfill gas

Additional Monitoring Requirements for Determination of VOC in Landfill Gas

The Owner or Operator shall determine the total VOC concentration in landfill gas, using Method 25C of Appendix A of 40 CFR 60, or other Department-

Annually EU22, EU23, and EU24

RSA 125-C:6 XI

TP-0065 Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

approved method, for the purposes of compliance with the recordkeeping and reporting requirements for VOC emissions as provided in items 2 and 16 of Table 7.

6. Flame Presence

Monitoring of Flare Operation

The landfill gas flares shall be equipped with instrumentation to monitor flame presence. The flame detection equipment shall operate continuously and shall signal an alarm whenever a flameout occurs. The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame.

Continuous EU02 and EU19 and any open

flare burning untreated landfill gas

40 CFR 60.18(c)(2) 60.18(f)(2) (Subpart A) TP-B-0525

Yes

7. Landfill gas flow rate

Monitoring of Landfill Gas Flow Rate

Flow measuring instrumentation shall be operated and maintained to measure the instantaneous flow rate and totalized flow, corrected for temperature and pressure, to each operating control device. This requirement shall apply at all times that landfill gas is delivered to a control device.

Note: In the case of the four engines (EU01 thru EU06), the Owner or Operator may elect to monitor total landfill gas flow to the engine plant and allocate the total flow to individual engines on the basis of recorded operating hours.

Continuous All landfill gas control devices

RSA 125-C:6 XI

FP-T-0168 TP-B-0525

Yes

8. Hydrogen Sulfide

LFG Sulfur Monitoring a. The Owner or Operator shall perform

landfill gas sulfur monitoring for TLR-I, -II, and -III and the engine plant, turbine plant and landfill gas header pipe to the UNH landfill gas treatment system in accordance with the provisions of the most recent Test Protocol for Landfill Gas Sulfur Monitoring, as approved by the Department.

Quarterly

EU03, EU04, EU05, EU06. EU08, EU09, and EU22, EU23, and

EU24

and UNH inlet header

pipe

RSA 125-C:6 XI

FP-T-0168

TP-0065

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

b. As an alternative to the method described in paragraph a. for TLR-III, the Owner or Operator may elect to install, operate, and maintain a continuous emissions monitoring device for hydrogen sulfide at the Turbine Plant. Monitoring for TLR-I and TLR-II under this alternative would continue as described in paragraph a.

Continuous for TLR-III;

Quarterly or semiannually for TLR-I and

TLR-II, as specified


Noted

Finding: TREE has not used an alternative method for sulfur monitoring as described in Item 8 b.

9. Sulfur content of landfill gas

NSPS Monitoring for Stationary Gas Turbines

The Owner or Operator shall monitor the total sulfur content of the fuel being fired in the turbines by using one of the approved methods identified below:

a. Daily sampling and testing by either: total sulfur methods described in 40 CFR 60.335(b)(10); or if the total sulfur content of the gaseous fuel during the most recent performance test was less than 0.4 weight percent (4000 ppmw), ASTM D4084–82, 94, D5504–01, D6228–98, or Gas Processors Association Standard 2377–86, which measure the major sulfur compounds; or

b. As an alternative to daily sampling and testing, the Owner or Operator may elect to sample and test sulfur content in conformance to the monitoring protocol and custom schedule issued and approved for the Facility by USEPA in a letter dated May 19, 1999.

Once per unit

operating day

(See schedule

established in

referenced letter)

EU08 and EU09

40 CFR 60.334,

paragraphs (h) and (i)

(Subpart GG) FP-T-0168

PO-B-2010 PO-B-2001

Yes

Finding: TREE has chosen to use the method in Item 9.b. to monitor the sulfur content of the fuel fired in EU08 and EU09. Currently, TREE is using the quarterly monitoring required in Table 6, Item #8.a. to comply with this requirement.

10. Sulfur Content of

Liquid & Gaseous

Fuels

a.) Conduct testing in accordance with appropriate ASTM test methods or retain maintain records in accordance with Table 7, Item 24 in order to demonstrate compliance with the sulfur content limitation

For each delivery of fuel oil to the facility

Facility-wide Env-A 806.02 &

Env-A 806.03 (Effective

10-31-2010)

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

provisions specified in this permit for liquid fuels.

b.) Conduct testing to determine the sulfur content in grains of sulfur per 100 cubic feet, of gaseous fuels.

Finding: TREE retains fuel oil delivery slips and maintains oil analysis data. TREE conducts quarterly testing of the LFG to determine the sulfur content of the LFG.

11. Annual Landfill

Gas Generation

Rate

Calculation of Annual LFG Generation Rate

a. The Owner or Operator shall calculate the predicted annual LFG generation rate and predicted annual gas collection rate in each of the next 25 years, at a minimum. Predicted annual LFG generation rates shall be developed using the latest version of USEPA’s LandGEM model with appropriate input values of k and Lo. Landfill gas collection efficiencies shall be based on EPA guidance for the appropriate cover type or as approved by DES for the appropriate cover type.

b. The predicted gas collection rates shall be compared with existing and planned landfill gas control capacities to assess future capacity needs.

Annually EU22, EU23, & EU23

RSA 125-C:6,XI

TP-0065

Yes

12. Equipment Accuracy

and Precision

Calibration requirements Calibration of the landfill gas flow, pressure and temperature monitoring devices following manufacturer’s recommended procedures shall occur at least once annually or in a manner and/or frequency approved by the Division.

Annually Facility-wide RSA 125-C:6, XI

TP-0065

No

Finding: A calibration for the MASS-tron II mass flow transmitter (SN 80877A) was not reported for 2018. A calibration of the mass flow transmitter occurred on July 22, 2019, and on August 2, 2019, TREE submitted a Factory Setup (FSU) Information Sheet to NHDES that demonstrated the unit meets manufacturer specifications.

13. Equipment time in service

Additional Monitoring Requirements for Gas Turbines and Engines

The Owner or Operator shall monitor the cumulative hours of operation of each

Continuous EU03, EU04, EU05, EU06, EU08, and

EU09

RSA 125-C:6, XI

TP-0065 Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

turbine and engine for the purposes of periodic maintenance and replacement in accordance with the manufacturer’s recommended service schedule for each device.

14. Electrical Power

Generation

Power Generation Monitoring and Calculations for NOx-Emitting Generation Sources The Owner or Operator shall determine electrical power generation by either of the following methods: a. By calculating actual electrical power

generation in MW-hr by multiplying the heat input in MMBtu obtained from fuel use records by 0.10 MW-hr/MMBtu, or

b. By monitoring electrical power generation in kW-hr using one of the monitors specified in Env-A 3705.01(b)(1).

Continuous until January

1, 2014

EU03 - EU06, EU08 and

EU09

State Enforceable

only Env-A

3705.01 FP-T-0168

Not Applicable

Finding: As of January 1, 2014, the above Item is longer required.

15. Opacity Measurem

ent

Opacity measurements shall be conducted following the procedures set forth in 40 CFR 60, Appendix A, Method 9, Visual Determination of the Opacity of Emissions from Stationary Sources.

Upon request by

NHDES/EPA

Facility-wide Env-A 807.02

Effective 10-31-2010

Noted

Finding: During the evaluation period, NHDES did not require any opacity measurements.

16. Hours of Operation

The Emergency Generator shall be equipped with a non-resettable hour meter.

Continuous EU07 40 CFR 63.6625, (Subpart

ZZZZ)

Yes

17. Startup Shutdown

and Malfunction

Plan

A written Startup Shutdown and Malfunction (SSM) Plan according to the provisions in 40 CFR 63.6(e)(3) must be developed. A copy of the SSM plan must be maintained on site. Failure to write or maintain a copy of the SSM plan is a deviation from the requirements of this subpart. This plan must contain all systems utilized to collect and control untreated landfill gas.

Maintain up to date

EU22, EU23, EU24 and

devices used to comply

with 40 CFR 60 Subpart WWW and 40 CFR 63 Subpart AAAA

40 CFR 63.1960 (Subpart

AAAA) and 40 CFR

63.6(e)(3)(i)

TP-0065

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

18. Various Wellhead Monitoring The Owner or Operator shall perform landfill gas collection system monitoring in accordance with the provisions of the modified Landfill Gas Collection and Control System (GCCS) Design Plan, as approved by the Department. This requirement does not replace, but is intended to supplement, NSPS requirements for gas collection and control system wellhead monitoring as

contained in 40 CFR 60.75060.759. a. The following well parameters shall

be monitored: 1. Well head temperature; 2. Landfill gas percentage oxygen

or nitrogen; 3. Landfill gas percentage

methane; 4. Wellhead pressure/vacuum; 5. For wells with orifice plates

installed, upstream-orifice and downstream-orifice pressure/vacuum or orifice differential measurements; and

6. Header-side pressure vacuum; b. For all wells with orifice plates

installed, calculate landfill gas flow rate from the parameters measured in a.5. above;

c. The nitrogen level shall be determined using Method 3C, unless an alternative test method is established as allowed by §60.752(b)(2)(i); and

d. Unless an alternative test method is established as allowed by §60.752(b)(2)(i), the oxygen shall be determined by an oxygen meter using Method 3A or 3C except that: 1. The span shall be set so that

the regulatory limit is between 20 and 50 percent of the span;

2. A data recorder is not required; 3. Only two calibration gases are

required, a zero and span, and

As specified in GCCS

Design Plan

EU22, EU23, EU24

RSA 125-C:6, XI

40 CFR 60.753

TP-0065

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

ambient air may be used as the span;

4. A calibration error check is not required; and

5. The allowable sample bias, zero drift, and calibration drift are ±10 percent.

Finding: During the on-site inspection, NHDES witnessed monitoring of three wellheads at TLR-III. Well number WP-572’s wellhead temperature was observed to be 142° F, 11 degrees above the 131°F action level established in the GCCS plan. In accordance with the GCCS Plan, a high temperature reading triggers the need to monitor for CO. TREE observed CO to be 0 ppm, well below the 100 ppm action level. CO levels above 100ppm indicate that a fire may be present. The corrective action taken by TREE during the inspection was to increase the flow at WP-572.

19. Enclosed Combustor Performance

Testing

Performance Test for Enclosed Combustors For the performance test required in §60.752(b)(2)(iii)(B), Method 25, 25C, or Method 18 of appendix A of this part must be used to determine compliance with the 98 weight-percent efficiency or the 20 ppmv outlet concentration level, unless another method to demonstrate compliance has been approved by the USEPA Administrator or the Department as provided by §60.752(b)(2)(i)(B). Method 3 or 3A shall be used to determine oxygen for correcting the NMOC concentration as hexane to 3 percent. In cases where the outlet concentration is less than 50 ppm NMOC as carbon (8 ppm NMOC as hexane), Method 25A should be used in place of Method 25. If using Method 18 of appendix A of this part, the minimum list of compounds to be tested shall be those published in the most recent Compilation of Air Pollutant Emission Factors (AP–42). The following equation shall be used to calculate efficiency: Control Efficiency = (NMOCin− NMOCout)/(NMOCin) where, NMOCin= mass of NMOC entering control device NMOCout= mass of NMOC exiting control device

Within 30 days of

initial start-up

EU15 40 CFR 60.754(d) (Subpart WWW)

Noted


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

Finding: TREE did not operate EU15 during the evaluation period. TREE has 120 days after the date on which the flare is initially operated to conduct the required performance test.

20. Open Flare Performance Testing

Performance Testing for Open Flares For the performance test required in §60.752(b)(2)(iii)(A), the net heating value of the combusted landfill gas as determined in §60.18(f)(3) is calculated from the concentration of methane in the landfill gas as measured by Method 3C. A minimum of three 30-minute Method 3C samples are determined. The measurement of other organic components, hydrogen, and carbon monoxide is not applicable. Method 3C may be used to determine the landfill gas molecular weight for calculating the flare gas exit velocity under §60.18(f)(4).

Within 30 days of

initial start-up

EU02 and EU19

40 CFR 60.754(e) (Subpart WWW)

Yes

Finding: TREE conducted compliance testing for EU02 and EU19 in accordance with §60.752(b)(2)(iii)(A) in June 2000 and August 2006, respectively.

21. LFG Generation

Compliance Provisions Except as provided in §60.752(b)(2)(i)(B), the specified methods in paragraphs a. through f. of this section shall be used to determine whether the gas collection system is in compliance with §60.752(b)(2)(ii). a. For the purposes of calculating the

maximum expected gas generation flow rate from the landfill to determine compliance with §60.752(b)(2)(ii)(A)( 1 ), one of the following equations shall be used. The k and Lo kinetic factors should be those published in the most recent Compilation of Air Pollutant Emission Factors (AP–42) or other site specific values demonstrated to be appropriate and approved by the USEPA Administrator for k and the Department or the USEPA Administrator for Lo. If k has been determined as specified in §60.754(a)(4), the value of k determined from the test shall be used. A value of no more than 15 years shall be used for the intended

Maintain up to date

EU22,EU23, and EU24

40 CFR 60.755(a)


Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

use period of the gas mover equipment. The active life of the landfill is the age of the landfill plus the estimated number of years until closure.

1. For sites with unknown year-to-year solid waste acceptance rate:

Qm= 2LoR (e−kc− e−kt)

where,

Qm= maximum expected gas generation flow rate, cubic meters per year

Lo= methane generation potential, cubic meters per megagram solid waste

R = average annual acceptance rate, megagrams per year

k = methane generation rate constant, year−1

t = age of the landfill at equipment installation plus the time the owner or operator intends to use the gas mover equipment or active life of the landfill, whichever is less. If the equipment is installed after closure, t is the age of the landfill at installation, years

c = time since closure, years (for an active landfill c = O and e−kc= 1)

2. For sites with known year-to-year solid waste acceptance rate:

where,


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

QM=maximum expected gas generation flow rate, cubic meters per year

k=methane generation rate constant, year−1

Lo=methane generation potential, cubic meters per megagram solid waste

Mi=mass of solid waste in the ithsection, megagrams

ti=age of the ithsection, years

3. Actual flow data may be used to project the maximum expected gas generation flow rate instead of, or in conjunction with, the equations in paragraphs a.1 and a.2. If the landfill is still accepting waste, the actual measured flow data will not equal the maximum expected gas generation rate, so calculations using the equations in paragraphs a.1 or a.2 or other methods shall be used to predict the maximum expected gas generation rate over the intended period of use of the gas control system equipment.

b. For the purposes of determining sufficient density of gas collectors for compliance with §60.752(b)(2)(ii)(A)( 2 ), the owner or operator shall design a system of vertical wells, horizontal collectors, or other collection devices, satisfactory to the USEPA Administrator or the Department, capable of controlling and extracting gas from all portions of the landfill sufficient to meet all operational and performance standards.

c. For the purpose of demonstrating whether the gas collection system flow rate is sufficient to determine compliance with §60.752(b)(2)(ii)(A)(


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

3 ), the owner or operator shall measure gauge pressure in the gas collection header at each individual well, monthly. If a positive pressure exists, action shall be initiated to correct the exceedance within 5 calendar days, except for the three conditions allowed under §60.753(b). If negative pressure cannot be achieved without excess air infiltration within 15 calendar days of the first measurement, the gas collection system shall be expanded to correct the exceedance within 120 days of the initial measurement of positive pressure. Any attempted corrective measure shall not cause exceedances of other operational or performance standards. An alternative timeline for correcting the exceedance may be submitted to the USEPA Administrator or the Department for approval.

d. For the purpose of identifying whether excess air infiltration into the landfill is occurring, the owner or operator shall monitor each well monthly for temperature and nitrogen or oxygen as provided in §60.753(c). If a well exceeds one of these operating parameters, action shall be initiated to correct the exceedance within 5 calendar days. If correction of the exceedance cannot be achieved within 15 calendar days of the first measurement, the gas collection system shall be expanded to correct the exceedance within 120 days of the initial exceedance. Any attempted corrective measure shall not cause exceedances of other operational or performance standards. An alternative timeline for correcting the exceedance may be submitted to the USEPA Administrator or the Department for approval.


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

e. An owner or operator seeking to demonstrate compliance with §60.752(b)(2)(ii)(A)( 4 ) through the use of a collection system not conforming to the specifications provided in §60.759 shall provide information satisfactory to the USEPA Administrator or the Department as specified in §60.752(b)(2)(i)(C) demonstrating that off-site migration is being controlled.

f. For purposes of compliance with §60.753(a), each owner or operator of a controlled landfill shall place each well or design component as specified in the approved design plan as provided in §60.752(b)(2)(i). Each well shall be installed no later than 60 days after the date on which the initial solid waste has been in place for a period of: 1. 5 years or more if active; or 2. 2 years or more if closed or at

final grade

22. Surface Methane Testing

Surface Methane Testing The following procedures shall be used for compliance with the surface methane operational standard as provided in §60.753(d). a. After installation of the collection

system, the owner or operator shall monitor surface concentrations of methane along the entire perimeter of the collection area and along a pattern that traverses the landfill at 30 meter intervals (or a site-specific established spacing) for each collection area on a quarterly basis using an organic vapor analyzer, flame ionization detector, or other portable monitor meeting the specifications provided in paragraph §60.755(d).

b. The background concentration shall be determined by moving the probe inlet upwind and downwind outside the boundary of the landfill at a

Quarterly EU22,EU23, and EU24

40 CFR 60.755(c)

Env-A 604.01

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

distance of at least 30 meters from the perimeter wells.

c. Surface emission monitoring shall be performed in accordance with section 8.3.1 of Method 21 of appendix A of this part, except that the probe inlet shall be placed within 5 to 10 centimeters of the ground. Monitoring shall be performed during typical meteorological conditions.

d. Any reading of 500 parts per million or more above background at any location shall be recorded as a monitored exceedance and the actions specified in paragraphs d.1 through d.5 of this section shall be taken. As long as the specified actions are taken, the exceedance is not a violation of the operational requirements of §60.753(d). 1. The location of each monitored

exceedance shall be marked and the location recorded.

2. Cover maintenance or adjustments to the vacuum of the adjacent wells to increase the gas collection in the vicinity of each exceedance shall be made and the location shall be re-monitored within 10 calendar days of detecting the exceedance.

3. If the re-monitoring of the location shows a second exceedance, additional corrective action shall be taken and the location shall be monitored again within 10 days of the second exceedance. If the re-monitoring shows a third exceedance for the same location, the action specified in paragraph d.5 of this section shall be taken, and no further monitoring of that location is required until the action specified in paragraph d.5 has been taken.


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

4. Any location that initially showed an exceedance but has a methane concentration less than 500 ppm methane above background at the 10-day re-monitoring specified in paragraph d.2 or d.3 of this section shall be re-monitored 1 month from the initial exceedance. If the 1-month remonitoring shows a concentration less than 500 parts per million above background, no further monitoring of that location is required until the next quarterly monitoring period. If the 1-month remonitoring shows an exceedance, the actions specified in paragraph d.3 or d.5 shall be taken.

5. For any location where monitored methane concentration equals or exceeds 500 parts per million above background three times within a quarterly period, a new well or other collection device shall be installed within 120 calendar days of the initial exceedance. An alternative remedy to the exceedance, such as upgrading the blower, header pipes or control device, and a corresponding timeline for installation may be submitted to the USEPA Administrator or the Department for approval.

6. The coordinates of each location where the surface methane concentration is 500 ppm or more above background concentration shall be located to within an accuracy of +/- 20 feet and marked on a base map of the Facility. A physical marker shall be placed on the landfill surface until the exceedance has been corrected.


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

e. The owner or operator shall implement a program to monitor for cover integrity and implement cover repairs as necessary on a monthly basis. The coordinates of each location of a deficiency in the landfill cover integrity shall be located to within an accuracy of +/- 20 feet and marked on a base map of the Facility. A physical marker shall be placed on the landfill surface until the deficiency has been corrected.

Finding: During this compliance evaluation, TREE followed the procedures above to demonstrate compliance with the surface methane operational standard. NHDES has granted a waiver every year of this compliance evaluation to postpone surface scanning for the first quarter due to unfavorable weather conditions (for monitoring) and unsafe walking conditions. These conditions include temperatures below 32 degree F and snow cover on landfill surfaces.

23. Testing Equipment Calibration

Surface Monitoring Equipment Testing Each owner or operator seeking to comply with the provisions in paragraph §60.755(c) shall comply with the following instrumentation specifications and procedures for surface emission monitoring devices: a. The portable analyzer shall meet the

instrument specifications provided in section 3 of Method 21 of appendix A of this part, except that “methane” shall replace all references to VOC.

b. The calibration gas shall be methane, diluted to a nominal concentration of 500 parts per million in air.

c. To meet the performance evaluation requirements in section 3.1.3 of Method 21 of appendix A of this part, the instrument evaluation procedures of section 4.4 of Method 21 of appendix A of this part shall be used.

d. The calibration procedures provided in section 4.2 of Method 21 of appendix A of this part shall be followed immediately before commencing a surface monitoring survey.

Immediately before

commencing a surface

monitoring survey

EU22,EU23, and EU24

40 CFR 60.755(d)

Yes


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Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

24. Various Wellhead Monitoring Except as provided in §60.752(b)(2)(i)(B), each owner or operator seeking to comply with §60.752(b)(2)(ii)(A) for an active gas collection system shall install a sampling port and a thermometer, other temperature measuring device, or an access port for temperature measurements at each wellhead and: a. Measure the gauge pressure in the

gas collection header on a monthly basis as provided in §60.755(a)(3);

b. Monitor nitrogen or oxygen concentration in the landfill gas on a monthly basis as provided in §60.755(a)(5); and

c. Monitor temperature of the landfill gas on a monthly basis as provided in §60.755(a)(5).

Monthly EU22,EU23, and EU24

40 CFR 60.756(a) (Subpart WWW)

Yes

25. Enclosed Combustor Temperature

and Flow

Enclosed Combustor Monitoring Except as provided in §60.752(b)(2)(i)(B), each owner or operator seeking to comply with §60.752(b)(2)(iii) using an enclosed combustor shall calibrate, maintain, and operate according to the manufacturer's specifications, the following equipment. a. A temperature monitoring device

equipped with a continuous recorder and having a minimum accuracy of ±1 percent of the temperature being measured expressed in degrees Celsius or ±0.5 degrees Celsius, whichever is greater. A temperature monitoring device is not required for boilers or process heaters with design heat input capacity equal to or greater than 44 megawatts.

b. A device that records flow to or bypass of the control device. If a bypass exists, the owner or operator shall either: 1. Install, calibrate, and maintain a

gas flow rate measuring device that shall record the flow to the

As Specified EU15 40 CFR 60.756(b) (Subpart WWW)

TP-B-0482

Noted


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

control device at least every 15 minutes; or

2. Secure the bypass line valve in the closed position with a car-seal or a lock-and-key type configuration. A visual inspection of the seal or closure mechanism shall be performed at least once every month to ensure that the valve is maintained in the closed position and that the gas flow is not diverted through the bypass line

Finding: TREE did not operate EU15 during the evaluation period.

26. Flare Flame

Presence and Flow

Open Flare Monitoring Except as provided in §60.752(b)(2)(i)(B), each owner or operator seeking to comply with §60.752(b)(2)(iii) using an open flare shall install, calibrate, maintain, and operate according to the manufacturer's specifications the following equipment: a. A heat sensing device, such as an

ultraviolet beam sensor or thermocouple, at the pilot light or the flame itself to indicate the continuous presence of a flame.

b. A device that records flow to or bypass of the flare. If a bypass exists, the owner or operator shall either: 1. Install, calibrate, and maintain a

gas flow rate measuring device that shall record the flow to the control device at least every 15 minutes; or

2. Secure the bypass line valve in the closed position with a car-seal or a lock-and-key type configuration. A visual inspection of the seal or closure mechanism shall be performed at least once every month to ensure that the valve is maintained in the closed position and that the gas flow is not diverted through the bypass line.

Continuous EU02 and EU19

40 CFR 60.756(c) (Subpart WWW)

Yes


of 86


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

Finding: EU02 and EU19 are not equipped with bypass systems. Upon detection of a loss of flame by the thermocouple the flare control system automatically shuts down the supply blower and closes the inlet control valve to prevent raw landfill gas from entering the flare.

27. Various Control System Monitoring Each owner or operator seeking to demonstrate compliance with §60.752(b)(2)(iii) using a device other than an open flare or an enclosed combustor shall provide information satisfactory to the USEPA Administrator or the Department as provided in §60.752(b)(2)(i)(B) describing the operation of the control device, the operating parameters that would indicate proper performance, and appropriate monitoring procedures. The USEPA Administrator or the Department shall review the information and either approve it, or request that additional information be submitted. The USEPA Administrator or the Department may specify additional appropriate monitoring procedures.

As specified in the GCCS Design Plan

Facility-wide and devices

used to comply with

40 CFR Subpart

WWW and 40 CFR 63 Subpart

AAAA

40 CFR 60.756(d) (Subpart WWW)

Yes

Finding: There is no monitoring currently required for any device other than open flare or enclosed combustor.

28. Various Collection System Monitoring Each owner or operator seeking to install a collection system that does not meet the specifications in §60.759 or seeking to monitor alternative parameters to those required by §60.753 through §60.756 shall provide information satisfactory to the USEPA Administrator or the Department as provided in §60.752(b)(2)(i) (B) and (C) describing the design and operation of the collection system, the operating parameters that would indicate proper performance, and appropriate monitoring procedures. The USEPA Administrator or the Department may specify additional appropriate monitoring procedures.

As specified in the GCCS Design Plan

EU22, EU23, EU24 and

devices used to comply

with 40 CFR Subpart

WWW and 40 CFR 63 Subpart

AAAA

40 CFR 60.756(e) (Subpart WWW)

Noted

Finding: TREE installed a LFG collection system that meets the requirements of § 60.759. TREE is not seeking to monitor alternative parameters to those required by §60.753 through §60.756.


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Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

29. Surface Methane

Surface Methane Monitoring Except as provided in §60.752(b)(2)(i)(B), each owner or operator seeking to demonstrate compliance with §60.755(c), shall monitor surface concentrations of methane according to the instrument specifications and procedures provided in §60.755(d). Any closed landfill that has no monitored exceedances of the operational standard in three consecutive quarterly monitoring periods may skip to annual monitoring. Any methane reading of 500 ppm or more above background detected during the annual monitoring returns the frequency for that landfill to quarterly monitoring.

Annual or Quarterly as

specified


40 CFR 60.756(f) (Subpart WWW)

Yes

30. Leachate Processed

The leachate concentrator shall be equipped with a flow meter capable of monitoring the volume of leachate processed.

Continuous EU25 RSA 125-C:6, XI

Yes

Finding: The leachate concentrator (EU25) was taken out of service in May of 2015. The leachate treatment facility has been upgraded, and the volume of leachate processed is monitored.

Table 3 below, taken from Permit TP-0205, lists the monitoring and testing requirements for the facility, and any deficiencies noted during the evaluation.

Table 3 - Monitoring and Testing Requirements

Item #

Parameter Method of Compliance Frequency Applicable Emission

Unit

Regulatory Basis

Compliant

1.

Sulfur Content of

Liquid Fuels

Conduct testing for each delivery of ULSD to the facility in accordance with appropriate ASTM test methods or retain documentation in accordance with Table 4, Item 1c in order to demonstrate compliance with the sulfur content limitation provisions specified in this permit for liquid fuels.

As specified

EU30

Env-A 806.02 &

Env-A 806.05

Yes

2. Hours of

Operation

The emergency engine shall be equipped with a non-resettable hour meter. Continuous EU30


IIII)

Yes


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Table 3 below, taken from Permit TP-0239, lists the monitoring and testing requirements for the facility, and any deficiencies noted during the evaluation.


Item #


Applicable Emission

Unit

Regulatory Citation

Compliant

1. Formaldehyde

Testing for Engines

The Owner or Operator shall conduct formaldehyde testing of each landfill gas-fired engines to demonstrate compliance with Table 2, Item 3. Compliance stack testing shall be conducted in accordance with Env-A 802. The following test methods, or department approved alternatives, shall be used as applicable:

a. EPA Method 320 or Method 323, to determine formaldehyde concentrations in stack gases;

b. Each performance test must be conducted in accordance with 40 CFR 60.8; and;

c. Conduct three separate test runs for each performance test required in this section, as specified in 40 CFR 60.8(f);

d. Each test run must be conducted within 10 percent of 100 percent peak (or highest achievable) load.

Once every 3 years,

concurrent with NOx

RACT Testing

EU03 – EU06

Env-A 802 and Env-A

809

Future Requirement

Finding: Formaldehyde testing is due to occur in the fourth quarter of 2020.

2. Formaldehyde

Testing Protocol

Compliance testing shall be planned and carried out in accordance with the following schedule: a. A pre-test protocol shall be submitted

to the department at least 30 days prior to the commencement of testing;

b. The Owner or Operator and any contractor retained by the Owner or Operator to conduct the test shall meet with a department representative at least 15 days prior to the test date to finalize the details of the testing; and

c. A test report shall be submitted to the department within 60 days after the completion of testing.

Once every 3 years,

concurrent with

NOx RACT Testing

EU03 – EU06

Env-A 802

Yes


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VII. Compliance with Recordkeeping Requirements Table 7 below, taken from Permit TV-0062, lists the recordkeeping requirements for the facility, and any deficiencies noted during the evaluation.

Table 7 - Applicable Recordkeeping Requirements

Item #

Applicable Recordkeeping Requirement Records

Retention/ Frequency

Applicable Emission

Unit

Regulatory Citation

Compliant

1.

The Permittee shall retain records of all required monitoring data, recordkeeping and reporting requirements, and support information for a period of at least 5 years from the date of origination.

Retain for a minimum of 5 years

Facility-wide

Env-A 902.01(a)

Yes

2.

The Permittee shall maintain records of monitoring requirements as specified in Table 6 of this Permit including: a. Summary of maintenance, calibration, and repair

records of the LFG flow, temperature and pressure monitoring devices;

b. Summary of LFG generation and collection; c. Summary of annual and quarterly testing of LFG

composition; d. VOC emission rate for all devices and processes; e. Changes to the Landfill Gas Collection and Control

System Design Plan; f. Changes to the SSM Plan; and g. Amount of leachate processed in the leachate

concentrator.

Maintain on a

continuous basis

Facility-wide

Env-A 906.01

TP-0065 Yes

3.

General Recordkeeping Requirements for Combustion Devices

The Owner or Operator shall maintain the following records of fuel characteristics and utilization for the fuels used in the combustion devices:

a. Type (e.g., landfill gas or Fuel Oil) and amount of fuel burned in each device;

b. Sulfur content of gaseous fuel burned in terms of grains sulfur per 100 scf of fuel, or percent sulfur by weight, at standard temperature and pressure;

c. For the monthly sulfur content, the Owner or Operator shall use the sampling as outlined in the following table:

Monthly Records Sulfur Sampling

January, February, March 1st Quarter Sampling

April, May, June 2nd Quarter Sampling

July, August, September 3rd Quarter Sampling

October, November, December

4th Quarter Sampling

Monthly All

combustion devices

Env-A 903.03

FP-T-0168 TP-B-0525 TP-B-0482

Yes


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Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

d. BTU content per cubic foot of landfill gas; and

e. Hours of operation for each device.

4.

Additional Recordkeeping Requirements for Gas Turbines and Engines

The Owner or Operator shall record the cumulative hours of operation of each turbine and engine pursuant to item 13 of Table 6.

Continuous

EU03, EU04, EU05, EU06, EU08, EU09

Env-A 906.01

TP-0065 Yes

5.

Additional Recordkeeping for Turbines A daily operation log shall be kept. This operating log shall include the following information: a. Hours of operation for each Turbine; b. Brake horsepower-hours of each turbine; c. Landfill gas flowrate of each turbine; d. Landfill gas nitrogen content as a percent volume at

15% oxygen content, dry basis; and e. Electrical generating loads.

Daily (report

Monthly)

EU08 and EU09

PO-B-2010 PO-B-2001 Yes

6.

Additional Recordkeeping for Flare 2 A daily operation log shall be kept. This operating log shall include the following information: a. Hours of operation; b. Landfill gas flowrate of the flare;

Daily EU02 PO-B-1927 Yes

7.

Additional Recordkeeping Requirements for CO, NOx and SO2

The Owner or Operator shall maintain a 12-month running total record of CO, NOx and SO2 emissions from all devices, including insignificant activities, for the purpose of demonstrating that emissions of these pollutants do not exceed the 12-month total emissions caps identified in items 2, 3, 25, 26, and 27 of Table 5.

Monthly Facility-

wide

Env-A 906.01 and

Env-A 604.02(a)(3 FP-T-0168 FP-B-0525

Yes

8.

Additional Recordkeeping Requirements for Testing of Landfill Gas Composition

The Owner or Operator shall keep a record of the date and test results for all samples collected and analyzed pursuant to the testing of landfill gas composition as described in item 8 of Table 6.

Maintain on a

continuous basis

EU03, EU04, EU05, EU06, EU08, EU09, EU22,

EU23, and EU24 and UNH inlet

header pipe

Env-A 906.01

TP-0065 Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

9.

Additional Recordkeeping for Gas Flow Rate

The Owner or Operator shall keep a record of all flow data recorded pursuant to item 7 of Table 6.

Continuous EU02, EU15 and EU19

Env-A 903.03, Env-A 906.01 & TP-B-0525

Yes

10.

Additional Recordkeeping for Flare Operation

Pursuant to item 6 of Table 6, the Owner or Operator shall keep a record of all periods during which the flare is not operating, including scheduled or unscheduled periods for service and unscheduled down time caused by flameout or other malfunction. The record shall include the reason for each outage, initial date and time of each outage, and the date and time that flare operation is restored.

Maintain on a

continuous basis

EU02, EU15, and

EU19

Env-A 906.01 &

TP-B-0525 Yes

11. The Permittee shall maintain annual records of actual emissions for each significant and insignificant activity for determination of emission based fees.

Maintain at facility at all times

Facility-wide

Env-A 705.03

Yes

12.

Regulated Toxic Air Pollutants

Documentation for the demonstration of compliance with Env-A 1400 shall be retained at the facility and shall be made available to DES for inspection.

Compliance was demonstrated at the time of permit issuance as described in the Division’s Application Review Summary for application # 10-0158. The source must update the compliance demonstration using one of the methods provided in Env-A 1405 if:

a. There is a revision to the list of RTAPs lowering the AAL for any RTAP emission from the Facility;

b. The amount of any RTAP emitted is greater than the amount that was evaluated in the Application Review Summary (e.g., use of a coating will increase);

c. An RTAP that was not evaluated in the Application Review Summary will be emitted (e.g., a new coating will be used); or

d. Stack conditions (e.g. air flow rate) change.

Maintain on a

continuous basis – Update prior to process changes

and within 90 days of

each revision of Env-A 1400

Facility-wide

Env-A 902.01 Env-A

1403.01(d) TP-0028

TP-B-0525

Yes

13.

General NOx Recordkeeping Requirements

If the actual annual NOx emissions from the Facility are greater than or equal to 10 tpy, the Owner or Operator shall record the following information:

a. Identification of each fuel burning device;

Continuous Facility-

wide

Env-A 905.02

FP-T-0168

FP-B-0525

FP-B-0482

Yes


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Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

b. Operating schedule during the high ozone season (June 1 through August 31) for each fuel burning device identified in (a.), above, including:

1. Hours and days of operation per calendar month;

2. Number of weeks of operation;

3. Type and amount of each fuel burned;

4. Heat input rate in MMBtu/hr;

5. Actual NOx emissions for the calendar year and a typical high ozone day during that calendar year; and

6. Emission factors and the origin of the emission factors used to calculate the NOx emissions.

14.

Recordkeeping for NOx-Emitting Generation Sources

The Owner or Operator shall maintain the following records for any NOx-emitting generation source:

a. Actual NOx emissions in accordance with the methods set forth in Env-A 616;

b. Fuel usage;

c. Hours of operation;

d. Power generation as monitored pursuant to Item 14 of Table 6;

e. Hours of downtime of the power generation monitoring system, if applicable, during the time period when the generator is in operation; and

f. Frequency and results of calibrations performed on the power generation monitoring system, as applicable.

Monthly until

January 1, 2014

EU03-EU06, EU08 and EU09

State only enforceable

Env-A 3706.01

FP-T-0168

Not Applicable

Finding: As of January 1, 2014 the above Item is longer required.

15.

General Recordkeeping Requirements for Process Operations

Maintain the following records for process operations: a. Total quantity of raw materials containing VOCs or

RTAPs; and

b. Hours of operation of each process.

Monthly EU21

Env-A 903.02

TP-0028 Yes

Finding: TREE tracks both the hours of spray time, and the total time the exhaust fan is running.


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

16.

VOC Emission Statements Recordkeeping Requirements

If the actual annual VOC emissions from all permitted devices located at the Facility are greater than or equal to 10 tpy, then record the following information: a. Identification of each VOC-emitting process or device

except for process or devices associated with non-core activities.;

b. The operating schedule during the high ozone season (June 1 through August 31) for each VOC-emitting process or device identified in a. above, including: 1. Typical hours of operation per day; and 2. Typical days of operation per calendar month.

c. The following VOC emission data from all VOC-emitting processes or devices identified in (a.) above, including:

1. Actual VOC emissions for: i. The calendar year, in tons; and ii. A typical high ozone season day during that

calendar year, in pounds per day; and 2. The emission factors and the origin of the emission

factors used to calculate the VOC emissions.

Maintain Up-to-Date

Data

Facility-wide

Env-A 904 TP-0028

Yes

17.

VOC Recordkeeping for Surface Coating and Printing Operations

If the actual annual VOC emissions from all permitted devices located at the Facility are greater than or equal to 10 tpy, then record the following information for each coating operation identified in Table 7, Item 16.a, above: a. Coating formulation and analytical data, as follows:

1. Supplier; 2. Name and color; 3. Type; 4. Identification number; 5. Density described as lb/gal; 6. Total volatile content described as weight percent; 7. Water content described as weight percent; 8. Exempt solvent content described as weight percent; 9. VOC content described as volume percent; 10. Solids content described as volume percent; 11. Diluent name and identification number; 12. Diluent solvent density described in lb/gal; 13. Diluent VOC content described as weight percent; 14. Diluent exempt solvent content described as weight percent; 15. Volume of diluent VOC described as gal; and 16. Diluent/solvent ratio described as gal diluent solvent per gal coating.

Maintain Up-to Date

Data EU21

Env-A 904.03

TP-0028 Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

b. The number of gallons of each coating, including solvents and diluents, utilized during a typical high ozone season day; and

c. Process information for a typical high ozone season day, including: 1. Method of application; 2. Number of coats; 3. Drying method; and 4. Substrate type and form

18.

NSPS Recordkeeping for Stationary Gas Turbines

The Owner or Operator shall record the sulfur content of the LFG fuel as determined by one of the approved procedures identified in Item 9 of Table 6. Records of sample dates, monitoring dates, and fuel supply shall be made available for inspection by USEPA or the Department upon request.

Varies with chosen method

EU08 and EU09

40 CFR 60.334(i)

(Subpart GG)

FP-T-0168

Yes

19.

Additional Recordkeeping Requirements for Gas Collection System Inoperability

Whenever any portion of the gas collection system is inoperable for more than 5 Days, the Owner or Operator shall record: a. Date(s) of inoperability; b. Identification of affected components (e.g., wells,

headers, etc.); c. Location of affected components, marked on a GIS base

map of the Facility; d. Nature or cause of inoperability; e. Corrective measures undertaken or proposed; and f. Date(s) of restoration of affected component(s) to full

operability.

Continuous EU22,

EU23, and EU24

Env-A 906.01

TP-0065

Yes

20.

Recordkeeping Requirements for Permit Deviations

a. Definitions: 1. A permit deviation is any occurrence that results in

an excursion from any emission limitation, operating condition, or work practice standard as specified in either a Title V permit, state permit to operate, temporary permit or general state permit issued by the Department.

2. An excess emission is an air emission rate that exceeds any applicable emission limitation.

3. A deviation is defined in §63.1990. For the purposes of the landfill monitoring and SSM plan requirements, deviations include the items in paragraphs a. through c. of this section.

As necessary

Facility-wide

40 CFR 63.1965 (Subpart AAAA)

Env-A 911.03

FP-T-0168

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

a. A deviation occurs when the control device operating parameter boundaries described in 40 CFR 60.758(c)(1) of subpart WWW are exceeded.

b. A deviation occurs when 1 hour or more of the hours during the 3-hour block averaging period does not constitute a valid hour of data. A valid hour of data must have measured values for at least three 15-minute monitoring periods within the hour.

c. A deviation occurs when a SSM plan is not developed or maintained on site

b. In the event of a permit deviation (including any excess emissions), the Owner or Operator of the affected device, process, or air pollution control equipment shall record the following information: 1. The permit deviation; 2. The probable cause of the permit deviation; 3. The date of the occurrence; 4. The duration; 5. The specific device that contributed to the permit

deviation; and 6. Any corrective or preventative measures taken.

21.

Startup Shutdown Malfunction Recordkeeping

Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. The owner or operator of an affected source subject to the provisions of this part shall maintain relevant records for such source of: a. The occurrence and duration of each startup or

shutdown when the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards;

b. The occurrence and duration of each malfunction of operation (i.e., process equipment) or the required air pollution control and monitoring equipment;

c. All required maintenance performed on the air pollution control and monitoring equipment;

d. Actions taken during periods of startup or shutdown when the source exceeded applicable emission limitations in a relevant standard and when the actions taken are different from the procedures specified in the

As Necessary

EU22, EU23, EU24

and devices used to comply with 40

CFR Subpart

WWW and 40 CFR 63 Subpart AAAA

40 CFR 60.7(b)

(Subpart A) 40 CFR 63.10

(Subpart A) TP-B-0482

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

affected source's startup, shutdown, and malfunction plan (see §63.6(e)(3)); or Actions taken during periods of malfunction (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) when the actions taken are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (see §63.6(e)(3));

e. All information necessary, including actions taken, to demonstrate conformance with the affected source's startup, shutdown, and malfunction plan (see §63.6(e)(3)) when all actions taken during periods of startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), and malfunction (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. (The information needed to demonstrate conformance with the startup, shutdown, and malfunction plan may be recorded using a “checklist,” or some other effective form of recordkeeping, in order to minimize the recordkeeping burden for conforming events);

22.

Recordkeeping for Continuous Monitoring Systems

Any owner or operator subject to the provisions of this part shall maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by this part recorded in a permanent form suitable for inspection. The file shall be retained for at least five years following the date of such measurements, maintenance, reports, and records.

Maintain up-to-date

EU08 and EU09

40 CFR 60.7(f)


Yes

23.

Operation Log for the Emergency Generator

The Owner or Operator shall keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-

Keep a running

Log EU07


ZZZZ)

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

emergency operation. If the engines are used for demand response operation, the owner or operator must keep records of the notification of the emergency situation, and the time the engine was operated as part of demand response.

Finding: TREE does not participate in demand response.

24.

Liquid Fuel Oil Recordkeeping Requirements

For stationary sources, the owner or operator shall maintain fuel delivery tickets that contain the following information: a. The date of delivery; b. The quantity of delivery;

For each delivery of fuel oil to the facility

Facility-wide

Env-A 806.05

(Effective 10-31-2010)

Yes

c. The name, address and telephone number of the company making the delivery; and

d. The maximum weight percentage of sulfur or a written statement from the fuel supplier that the sulfur content of the fuel as delivered does not exceed standards listed in this permit for that fuel.

Whenever there is a change in

fuel supplier

but at least annually

Yes

25.

Recordkeeping Requirements for Landfill Monitoring and Testing

The Owner or Operator shall maintain all records necessary to demonstrate compliance with the provisions for wellhead monitoring, surface methane monitoring, landfill cover integrity monitoring, and sulfur monitoring identified in Table 6. This requirement does not replace, but is intended to supplement, NSPS recordkeeping requirements associated with landfill monitoring/testing as provided in 40 CFR 60.758.

As specified in

GCCS Design Plans

EU22, EU23, EU24

TP-0065 Yes

26.

Additional Recordkeeping Requirements for Determination of Annual LFG Generation Rate

The Owner or Operator shall maintain records of all input data, calculations, and model outputs assembled and developed pursuant to the determination of annual LFG generation rate as described in item 11 of Table 6.

Annually EU22,

EU23, and EU24

Env-A 906.01

TP-0065

Yes

27.

MSWLF Design Capacity Recordkeeping

Except as provided in §60.752(b)(2)(i)(B), each owner or operator of an MSW landfill subject to the provisions of §60.752(b) shall keep for at least 5 years up-to-date, readily accessible, on-site records of the design capacity report which triggered §60.752(b), the current amount of solid waste in-place, and the year-by-year waste acceptance rate. Off-site records may be maintained if they are retrievable

Maintain up-to-date

EU22, EU23, and

EU24

40 CFR 60.758(a)

(Subpart WWW)

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

within 4 hours. Either paper copy or electronic formats are acceptable.

28.

Collection and Control System Recordkeeping

Except as provided in §60.752(b)(2)(i)(B), each owner or operator of a controlled landfill shall keep up-to-date, readily accessible records for the life of the control equipment of the data listed in paragraphs a. through d. of this section as measured during the initial performance test or compliance determination. Records of subsequent tests or monitoring shall be maintained for a minimum of 5 years. Records of the control device vendor specifications shall be maintained until removal. a. Where an owner or operator subject to the provisions of

this subpart seeks to demonstrate compliance with §60.752(b)(2)(ii): 1. The maximum expected gas generation flow rate as

calculated in §60.755(a)(1). The owner or operator may use another method to determine the maximum gas generation flow rate, if the method has been approved by the Department or the USEPA Administrator and if a site-specific k value is used by the USEPA Administrator.

2. The density of wells, horizontal collectors, surface collectors, or other gas extraction devices determined using the procedures specified in §60.759(a)(1).

b. Where an owner or operator subject to the provisions of this subpart seeks to demonstrate compliance with §60.752(b)(2)(iii) through use of an enclosed combustion device: 1. The average combustion temperature measured at

least every 15 minutes and averaged over the same time period of the performance test.

2. The percent reduction of NMOC determined as specified in §60.752(b)(2)(iii)(B) achieved by the control device.

c. Where an owner or operator subject to the provisions of this subpart seeks to demonstrate compliance with §60.752(b)(2)(iii)(A) through use of an open flare, the flare type (i.e., steam-assisted, air-assisted, or nonassisted), all visible emission readings, heat content determination, flow rate or bypass flow rate measurements, and exit velocity determinations made during the performance test as specified in §60.18;

Maintain up-to-date

EU22, EU23, EU24


CFR Subpart


40 CFR 60.758(b)

(Subpart WWW)

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

continuous records of the flare pilot flame or flare flame monitoring and records of all periods of operations during which the pilot flame of the flare flame is absent.

29.

Operating Parameter Recordkeeping

Except as provided in §60.752(b)(2)(i)(B), each owner or operator of a controlled landfill subject to the provisions of this subpart shall keep for 5 years up-to-date, readily accessible continuous records of the equipment operating parameters specified to be monitored in §60.756 as well as up-to-date, readily accessible records for periods of operation during which the parameter boundaries established during the most recent performance test are exceeded. a. The following constitute exceedances that shall be

recorded and reported under §60.757(f) shall include for enclosed combustors, all 3-hour periods of operation during which the average combustion temperature was more than 28oC below the average combustion temperature during the most recent performance test at which compliance with §60.752(b)(2)(iii) was determined.

b. Each owner or operator subject to the provisions of this subpart shall keep up-to-date, readily accessible continuous records of the indication of flow to the control device or for a control device where a bypass exists, the indication of bypass flow or records of monthly inspections of car-seals or lock-and-key configurations used to seal bypass lines, specified under §60.756.

c. Each owner or operator seeking to comply with the provisions of this subpart by use of an open flare shall keep up-to-date, readily accessible continuous records of the flame or flare pilot flame monitoring specified under §60.756(c), and up-to-date, readily accessible records of all periods of operation in which the flame or flare pilot flame is absent.

Maintain up-to-date

EU22, EU23, EU24


CFR Subpart


40 CFR 60.758(c)

(Subpart WWW)

TP-B-0482

Yes

30.

Except as provided in §60.752(b)(2)(i)(B), each owner or operator subject to the provisions of this subpart shall keep for the life of the collection system an up-to-date, readily accessible plot map showing each existing and planned collector in the system and providing a unique identification location label for each collector. a. Each owner or operator subject to the provisions of this

subpart shall keep up-to-date, readily accessible records

Maintain up-to-date

EU22, EU23, and

EU24

40 CFR 60.758(d)

(Subpart WWW)

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

of the installation date and location of all newly installed collectors as specified under §60.755(b).

b. Each owner or operator subject to the provisions of this subpart shall keep readily accessible documentation of the nature, date of deposition, amount, and location of asbestos-containing or nondegradable waste excluded from collection as provided in §60.759(a)(3)(i) as well as any nonproductive areas excluded from collection as provided in §60.759(a)(3)(ii).

31.

Except as provided in §60.752(b)(2)(i)(B), each owner or operator subject to the provisions of this subpart shall keep for at least 5 years up-to-date, readily accessible records of all collection and control system exceedances of the operational standards in §60.753, the reading in the subsequent month whether or not the second reading is an exceedance, and the location of each exceedance.

Maintain for at least 5 years up-

to-date

EU22, EU23, EU24


CFR Subpart


40 CFR 60.758(e)

(Subpart WWW)

Yes

32.

General Recordkeeping Requirements for Process Operations

Maintain the following records for process operations: a. Total quantity of leachate processed; and

b. Hours of operation of the leachate concentrator.

Monthly EU25 Env-A

903.02 Not

Applicable

Finding: EU25 did not operate this evaluation period. The concentrator was disconnected in 2015 and will be removed from the facility in the near future.

33.

EU29 Recordkeeping Requirements

a.) Keep records of maintenance conducted on EU29. Maintenance should be conducted in accordance with manufacturer’s recommendations.

b.) Keep documentation from the manufacturer that the engine is certified to meet the emission standards per 40 CFR part 90

As needed EU29

40 CFR 60.4243(a)

& 40 CFR

60.4231

Yes

34.

Gaseous Fuel Recordkeeping Requirements

Maintain one of the following: a. Sulfur content as percent sulfur by weight or in grains

per 100 cubic feet of fuel; b. Documentation that the fuel source is from a utility

pipeline; or c. Documentation that the fuel meets state sulfur limits.

For each delivery of LPG fuel to the Facility

or whenever there is a change in

EU29 & EU28

Env-A 903.03

Yes


of 86


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

natural gas fuel

supplier, but at least

annually

Table 4 below, taken from Permit TP-0205, lists the recordkeeping requirements for the facility, and any deficiencies noted during the evaluation.

Table 4 - Recordkeeping Requirements

Item #

Requirement Duration/ Frequency

Applicable Unit

Regulatory Basis

Compliant

1.

General Recordkeeping Requirements for Combustion Devices

Maintain the following records of fuel characteristics and utilization for the fuel used in the combustion devices:

a. Type (e.g. #2 fuel, ULSD, natural gas) and amount of fuel burned in each device or type and amount of fuel burned in multiple devices and hours of operation of each device to be used to apportion fuel use between the multiple devices;

b. Total hours of operation of each emergency generator; and

Monthly

EU30

Env-A 903.03,

Env-A 906

Yes

c. Documentation that the liquid fuel meets sulfur limits.

Whenever there is a change in

fuel supplier

but at least annually

Yes

2.

NSPS Subpart IIII Recordkeeping Requirements

The owner or operator shall maintain the following records:

a. Documentation from the engine manufacturer certifying that the engine complies with the applicable emission standards stated in 40 CFR Part 60, Subpart IIII; and

b. A copy of the manufacturer's O&M manual for the engine.

Maintain for the life

of the engine

EU30

40 CFR 60.4211

(Subpart IIII)

Yes


of 86

Table 4 - Recordkeeping Requirements

Item #

Requirement Duration/ Frequency

Applicable Unit

Regulatory Basis

Compliant

Additional Recordkeeping Requirements for Emergency Engines Subject to NSPS Regulations

The owner or operator shall maintain the following records:

c. The maintenance conducted on the engines in order to demonstrate that the devices were operated and maintained according to the O&M manual;

d. The operation of the engine in emergency (i.e. loss of power) that are recorded through the non-resettable hour meter. The owner or operator must record the time of operation of the engine and the reason the engine was in operation during that time; and

e. Documentation of the federal, state or local standard(s) that require the owner or operator to conduct maintenance and testing for more than 100 hours per calendar year if the owner or operator is exercising the option listed in Table 2, Item 6b.

Maintain Up-to-date

Data EU30

40 CFR 60.4211, 40 CFR

60.4214 (Subpart

IIII), &

Env-A 906

Yes

Table 4 below, taken from Permit TP-0239, lists the recordkeeping requirements for the facility, and any deficiencies noted during the evaluation.


Item #



Applicable Emission

Unit

Regulatory Citation

Compliant

1.

Additional Recordkeeping Requirements for HAPs Emission Limitation

Maintain a 12-month running total of formaldehyde and total HAP emissions, calculated pursuant to Env-A 705.03, for the purpose of demonstrating that emissions of these pollutants do not exceed the major source thresholds identified in Table 2, Item 1.

Monthly Facility-

wide

Env-A 906 and Env-A 604.02(a)3

Yes

Finding: Currently, TREE is calculating fugitive emissions of formaldehyde from its landfills using an emission factor which is regarded as draft until formal release through EPA’s Technology Transfer Network (TTN) Clearinghouse for Inventories & Emission. During the on-site inspection, TREE expressed interest in testing LFG for formaldehyde to develop a site specific emission factor for fugitive emissions of formaldehyde.

2.

Additional Recordkeeping Requirements for RTAP Operating Limitations

Maintain records documenting the date and times of day each engine is operated to demonstrate compliance with Table 2, Item 2.

Daily EU03 – EU06

Env-A 906 and Env-A

1400

(State-only Enforceable

Limit)

Yes


of 86

VIII. Compliance with Reporting Requirements Table 8 below, taken from permit TV-0062, lists the reporting requirements for the facility, and any deficiencies noted during the evaluation.

Table 8 - Applicable Reporting Requirements

Item #

Reporting Requirements Frequency

of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

1.

Availability of Records to the Public

All data submitted to the Department, including emission data and applicable emission limitations, shall be available to the public.

Continuous Facility-

wide

Env-A 902.01

FP-B-0482 FP-B-0525 TP-0065

Yes

2.

Annual Emissions Report

The Owner or Operator shall submit an annual emissions report which shall include the following information:

a. Actual calendar year emissions from each device or area source of NOx, CO, SO2, TSP, and VOCs (speciated by individual VOC), {fuel burning devices do not need to speciate VOCs} HAPs (speciated by individual HAP), and RTAPs (speciated by individual RTAP);

b. For calculating SO2 emissions and H2S emissions, the following sampling results shall be used:

Months Reporting Sulfur Sampling

January, February, March 1st Quarter Sampling Results

April, May, June 2nd Quarter Sampling Results

July, August, September 3rd Quarter Sampling Results

October, November, December

4th Quarter Sampling Results

c. The methods used in calculating such emissions in accordance with Env-A 705.02, Determination of Actual Emissions for Use in Calculating Emission-Based Fees; and

d. All information recorded in accordance with Item 15 of Table 7.

Annually

(received by DES no later

than April 15th of the

following year)

Facility-wide

Env-A 907.01

TP-0028 FP-T-0168 FP-B-0525 FP-B-0482 TP-0065

Yes

3.

Additional Reporting Requirements for Testing of Landfill Gas Composition

The Owner or Operator shall submit to the Department within 30 days after the information becomes available all analytical test results obtained pursuant to the periodic testing of landfill gas composition as described in items 5 and 8 of Table 6.

Quarterly or

annually, as set forth

in item 5 and 8 of Table 6

EU03, EU04, EU05, EU06. EU08,

EU09, and; EU22,

EU23, and EU24;

Env-A 910.01 &

TP-B-0525

TP-0065

Yes


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

and UNH inlet

header pipe

4.

Additional Reporting Requirements for CO, NOx, and SO2

The Owner or Operator shall include in the annual emissions report identified in Item 1 above all data collected pursuant to Item 7 of Table 7.

Annually (received by DES no later


following year)

Facility-wide

Env-A 910.01

FP-T-0168 FP-B-0525

Yes

5.

NOx Emission Statements Reporting Requirements

If the actual annual NOx emissions for the Facility are greater than or equal to 10 tpy, the Owner or Operator shall include the following information in the annual emission report identified in Item 1 above:

a. A breakdown by month of NOx emissions; and

b. All data recorded pursuant to Item 13 of Table 7.


than April 15th of the following

year)

Facility-wide

Env-A 909 and

Env-A 910.01

FP-T-0168 FP-B-0525 TP-B-0482

Yes

6.

VOC Emission Statements Reporting Requirements

If the actual annual VOC emissions from all permitted devices located at the TREE Facility are greater than or equal to 10 tpy, then include the following information with the annual emission report: a. Facility information, including:

1. Source name; 2. Standard Industrial Classification (SIC) code; 3. North American Industrial Classification System

(NAICS) code; 4. Physical and mailing addresses; and

b. A breakdown of VOC emissions reported pursuant to Table 8, Item 2 by month; and

c. All data recorded pursuant to Table 7, Items 16 and 17.



year)

Facility-wide at the

TREE facility

Env-A 908 TP-0028

Yes

7.

Reporting Requirements for NOx-Emitting Generation Sources

The Owner or Operator shall include in the annual emissions report identified in Item 2 above all data collected pursuant to Item 14 of Table 6.



year) with the last report

due on April 15, 2014

EU03-EU06,

EU08, and EU09

State only Enforceable

Env-A 3707.03

Not Applicable

Finding: The above Item was not required this evaluation period.


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

8.

Additional Reporting Requirements for Calculation of Annual LFG Generation Rate, etc.

The Owner or Operator shall include in the annual report identified in item 2 of Table 8 the following information relative to the determination of annual LFG generation rate as described in item 11 of Table 6:

a. All input data, calculations, and LandGEM model outputs for each set of k and Lo values;

b. Narrative description of the various model outputs and the choice of k and Lo values used for predicting future methane generation rates;

c. Narrative description and supporting calculations showing predicted methane generation rates and anticipated gas collection rates based on different cover types; and

d. Narrative description comparing anticipated gas generation and collection rates vs. existing and planned landfill gas control capacities, including an assessment of future capacity needs.

Annually EU22,

EU23, and EU24

Env-A 604.01 & TP-

B-0525

TP-0065

Yes

9.

Additional Reporting Requirements for the GCCS Design Plan.

The Owner or Operator shall include in the semi-annual landfill NSPS-MACT compliance report identified in Table 8, item 19 a summary of changes to the Landfill Gas Collection and Control System Design Plan.

Semi-Annually, no later than 30

days after the

conclusion of the

semiannual period

EU22, EU23, and EU24 and devices used to comply with 40 CFR 60 Subpart


Env-A 910.01

& 40 CRR Part 60 Subpart

WWW &

40 CFR Part 63 Subpart

AAAA &

TP-0065

Yes

10.

Additional Reporting Requirements for Surface Methane Monitoring and Landfill Cover Integrity Monitoring

The quarterly surface methane monitoring and landfill cover integrity report identified in the GCCS Design Plan shall include:

a. An assessment of the surface methane monitoring and landfill cover integrity programs, providing summaries of:

1. Surface methane monitoring results (exceedances found) and landfill cover integrity check (deficiencies found) for the quarterly reporting period;

Quarterly, no later than 60

days after the

conclusion of each

calendar quarter.

EU22, EU23, and

EU24

Env-A 910.01

TP-0065

Yes


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

2. Known or probable causes of observed exceedances and deficiencies;

3. Actions taken to correct exceedances and deficiencies, including any uncorrected exceedances and deficiencies remaining from previous quarterly monitoring periods; and

4. Actions remaining to be taken to correct any uncorrected exceedances and deficiencies; and

b. All information described in the current GCCS Design Plan under the heading “SEM Reporting.”

11.

NSPS Reporting for Stationary Gas Turbines

The Owner or Operator shall submit reports of excess emissions and monitor downtime, in accordance with 40 CFR 60.7(c). Excess emissions shall be reported for all periods of unit operation, including startup, shutdown and malfunction. Periods of excess emissions and monitor downtime that shall be reported are defined as follows:

a. Sulfur dioxide: A period of monitor downtime begins when a required sample is not taken by its due date. A period of monitor downtime also begins on the date and hour of a required sample, if invalid results are obtained. The period of monitor downtime shall include only unit operating hours, and ends on the date and hour of the next valid sample.

b. All reports required under 40 CFR 60.7(c) shall be postmarked by the 30th day following the end of each 6-month period.

Semi-annually

EU08, and EU09

40 CFR 60.334(j) (Subpart

GG) FP-T-0168

Yes

12.

Semi-Annual Permit Deviation and Monitoring Report

The Permittee shall submit a summary report of monitoring, testing, and Permit deviations every 6 months. The report shall contain the following data: a. Summary of maintenance, calibration, and repair

records of the landfill gas flow, temperature, and pressure monitoring devices;

b. Summary of landfill gas flow; and c. A summary of all permit deviations recorded pursuant

to Condition XXVIII of this Permit that occurred during the reporting period.

Semi-annually

(Received by DES by July

31st and January 31st of each calendar

year)

Facility-wide

Env-A 907.04(b) TP-0065

Yes

13.

Startup, Shutdown and Malfunction Report

Reports on all startup, shutdown, and malfunctions must be submitted in accordance with the general provisions of 40 CFR 63.10(d)(5). If actions taken during a startup, shutdown and malfunction plan are consistent with the procedures in

Semi-annual

report or as indicated

Facility-wide

40 CFR 63.1980(b)

(Subpart AAAA)

Yes


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

the startup, shutdown and malfunction plan, this information shall be included in a semi-annual startup, shutdown and malfunction plan report. Any time an action taken during a startup or shutdown that caused the source to exceed any applicable emission limitation in the relevant emission standards or a malfunction that is not consistent with the startup, shutdown and malfunction plan, the source shall report actions taken within 2 working days after commencing such actions, followed by a letter within 7 working days after the event.

40 CFR

63.10(d)(5) (Subpart A)

14.

Excess Emissions and Monitoring System Report

Each owner or operator required to install a continuous monitoring device shall submit excess emissions and monitoring systems performance report (excess emissions are defined in applicable subparts) and-or summary report form (see paragraph (d) of this section) to the USEPA Administrator and the Department semiannually, except when: more frequent reporting is specifically required by an applicable subpart; or the USEPA Administrator or the Department, on a case-by-case basis, determines that more frequent reporting is necessary to accurately assess the compliance status of the source. All reports shall be postmarked by the 30th day following the end of each six-month period. Written reports of excess emissions shall include the following information: a. The magnitude of excess emissions computed in

accordance with §60.13(h), any conversion factor(s) used, and the date and time of commencement and completion of each time period of excess emissions. The process operating time during the reporting period.

b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility. The nature and cause of any malfunction (if known), the corrective action taken or preventative measures adopted.

c. The date and time identifying each period during which the continuous monitoring system was inoperative except for zero and span checks and the nature of the system repairs or adjustments.

d. When no excess emissions have occurred or the continuous monitoring system(s) have not been inoperative, repaired, or adjusted, such information shall be stated in the report.

Semi-annual Report

EU08, EU09,

40 CFR 60.7(c)


Yes

15. Payment of Emission-Based Fee Annually

(Received by DES no later

Significant &

Env-A 705.04

Yes


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

Annual reporting of emission based fees shall be conducted in accordance with Section XIV of this Permit. The Owner or Operator shall submit, to the Division, payment of the emission-based fee by April 15th for emissions during the previous calendar year. For example, the fees for calendar year 2011 shall be submitted on or before April 15, 2012.


following year)


TP-0028 TP-B-0525

16.

Annual Compliance Certification

Submit an annual compliance certification to the Division and USEPA which includes the following information for each and every requirement and condition of the facilities effective permit: a. The particular permit condition or item number that

references each requirement, and a brief summary of the requirement;

b. The compliance status with respect to the requirement and whether during the year compliance with the requirement was continuous, intermittent, not achieved, or not applicable;

c. The method(s) used to determine compliance, such as monitoring, record keeping, or test methods;

d. The frequency, either continuous or intermittent, of the method(s) used to determine compliance;

e. If compliance was not continuous, a description of each permit deviation; and

f. Any additional information required in order for the Division to determine the compliance status of the source.

Annually

(Received by DES no later than

April 15th of the

following year)

Facility-wide

Env-A 907.04(a) TP-0028 TP-0065

Yes

17.

Calculation of NOx Emissions for One or More NOx-Emitting Generation Sources Located at a Single Stationary Source

The Owner or Operator shall calculate average monthly emissions from the generators using the following equation:

E = (A1 + A2 + ... + An) - [(7 + C) x (B1 + B2 + … + Bn)] 2000 where:

E = The total NOx emissions in tons per month; A = The actual NOx emissions in tons per month for each generator; B = The actual power generation for each generator in megawatt-hours of electricity produced per month; and

C = NOx emissions rate in pounds of NOx emitted for each megawatt-hour of electricity produced per month that are attributable to the provision of other,

Annually until

January 1, 2014

EU03-EU06, EU08 and EU09

Env-A 3704.01

(effective 12-20-2001)

State-only enforceable

Not Applicable


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

non-electric services and that are exempted from the fee calculation in accordance with Env-A 3703.02.

Finding: As of January 1, 2014, NOx Fund fee emission calculations are no longer required. The final report required under this provision was submitted in April 2014.

18.

Each owner or operator subject to the requirements of 40 CFR 60 Subpart WWW is exempted from the requirements of paragraphs §60.757(b)(1) and §60.757(b)(2), after the installation of a collection and control system in compliance with §60.752(b)(2), during such time as the collection and control system is in operation and in compliance with §§60.753 and 60.755.

Exempted from

Reporting

EU22, EU23, and

EU24

40 CFR 60.757(b)3

(Subpart WWW)

Noted

Finding: This requirement describes an exemption that is applicable to current gas collection and control operations at TREE.

19.

Semi-annual Compliance Reporting

Each owner or operator of a landfill seeking to comply with §60.752(b)(2) using an active collection system designed in accordance with §60.752(b)(2)(ii) shall submit to the USEPA Administrator and the Department semi-annual reports of the recorded information in (a) through (f) below. The initial report shall be submitted within 180 days of installation and start-up of the collection and control system, and shall include the initial performance test report required under §60.8. For enclosed combustion devices and flares, reportable exceedances are defined under §60.758(c). a. Value and length of time for exceedance of applicable

parameters monitored under §60.756(a), (b), (c), and (d). b. Description and duration of all periods when the gas

stream is diverted from the control device through a bypass line or the indication of bypass flow as specified under §60.756.

c. Description and duration of all periods when the control device was not operating for a period exceeding 1 hour and length of time the control device was not operating.

d. All periods when the collection system was not operating in excess of 5 days.

e. The location of each exceedance of the 500 parts per million methane concentration as provided in §60.753(d) and the concentration recorded at each location for which an exceedance was recorded in the previous month.

f. The date of installation and the location of each well or collection system expansion added pursuant to paragraphs (a)(3), (b), and (c)(4) of §60.755.

Semi-annually

EU22, EU23, EU24


CFR Subpart


40 CFR 60.757(f) (Subpart WWW)

40 CFR

63.1980(a) (Subpart AAAA)

Yes


of 86


Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

20.

Each owner or operator seeking to comply with §60.752(b)(2)(iii) shall include the following information with the initial performance test report required under §60.8: a. A diagram of the collection system showing collection

system positioning including all wells, horizontal collectors, surface collectors, or other gas extraction devices, including the locations of any areas excluded from collection and the proposed sites for the future collection system expansion;

b. The data upon which the sufficient density of wells, horizontal collectors, surface collectors, or other gas extraction devices and the gas mover equipment sizing are based;

c. The documentation of the presence of asbestos or nondegradable material for each area from which collection wells have been excluded based on the presence of asbestos or nondegradable material;

d. The sum of the gas generation flow rates for all areas from which collection wells have been excluded based on nonproductivity and the calculations of gas generation flow rate for each excluded area; and

e. The provisions for increasing gas mover equipment capacity with increased gas generation flow rate, if the present gas mover equipment is inadequate to move the maximum flow rate expected over the life of the landfill; and

f. The provisions for the control of off-site migration.

As Specified

EU22, EU23, EU24


CFR Subpart


40 CFR 60.757(g) (Subpart WWW)

Yes


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Item #


of Reporting

Applicable Emission

Unit

Regulatory Citation

Compliant

21.

General Notification Requirements

Any owner or operator subject to the provisions of this part shall furnish the USEPA Administrator and the Department written notification or, if acceptable to both the USEPA Administrator and the Department and the owner or operator of a source, electronic notification, as follows: a. A notification of the date construction (or reconstruction

as defined under §60.15) of an affected facility is commenced postmarked no later than 30 days after such date. This requirement shall not apply in the case of mass-produced facilities which are purchased in completed form.

b. A notification of the actual date of initial startup of an affected facility postmarked within 15 days after such date.

c. A notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, unless that change is specifically exempted under an applicable subpart or in §60.14(e). This notice shall be postmarked 60 days or as soon as practicable before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The USEPA Administrator or the Department may request additional relevant information subsequent to this notice.

d. A notification of the date upon which demonstration of the continuous monitoring system performance commences in accordance with §60.13(c). Notification shall be postmarked not less than 30 days prior to such date.

e. A notification of the anticipated date for conducting the opacity observations required by §60.11(e)(1) of this part. The notification shall also include, if appropriate, a request for the USEPA Administrator or the Department to provide a visible emissions reader during a performance test. The notification shall be postmarked not less than 30 days prior to such date.

As Specified

EU08, EU09, EU22,

EU23, EU24 and

devices used to comply with 40

CFR Subpart


40 CFR 60.7(a)

(Subpart A) Yes


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Table 5 below, taken from permit TP-0205, lists the reporting requirements for the facility, and any deficiencies noted during the evaluation.

Table 5 - Reporting Requirements

Item #

Requirement Frequency Applicable Emission

Unit

Regulatory Basis

Compliant

22.

General Reporting Requirements a. Each report shall be separately and clearly labeled with:

1. The name, mailing address and physical address of the source covered by the report;

2. The operating period covered by the report; 3. The permit number and condition or item number

that requires the report submittal; 4. The type of report, using the name of the report as

specified in the reporting condition in the permit, that is being submitted; and

5. The date the report was prepared; b. An owner or operator who submits a report that is a

revision to a previously-submitted report shall clearly identify the revised report with the information specified in Table 5, Item 1a. above, and indicate which portions of the report have been revised;

c. The owner or operator may submit more than one report with a single cover, provided the owner or operator clearly identifies each report being submitted using the information required in Table 5, Items 1a. and 1b. above, if applicable, for each report; and

d. The owner or operator shall submit reports as paper documents or by electronic means.

For each report

submitted to the

department

Facility Wide

Env-A 907.01

Yes

2.

23.

Annual Emissions Report Submit an annual emissions report which shall include the following information: a. Actual calendar year emissions from each emission unit

of NOx, CO, SO2, total filterable PM, and total VOCs; b. The methods used in calculating such emissions in

accordance with Env-A 705.02, Determination of Actual Emissions for Use in Calculating Emission-Based Fee;

c. The emission factors and the origin of the emission factors; and

d. All information recorded in accordance with Table 4, Item 1.

Annually (received by

the department

no later than April

15th of the following

year)

EU30 Env-A 907.02

Yes

2 24.

Permit Deviation Reporting Requirements Report permit deviations that cause excess emissions and/or monitoring parameter excursions lasting 48 hours or more in accordance with Condition VII.B.

As specified EU30 Env-A

911.04 (a) and (d)

Yes


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Table 5 - Reporting Requirements

Item #

Requirement Frequency Applicable Emission

Unit

Regulatory Basis

Compliant

25. Emission Based Fee Pay emission-based fees in accordance with Condition X.

Annually (received by department

no later than April

15th of the following

year)

EU30 Env-A 705 Yes

IX. Permit Deviation Reporting Requirements

During the evaluation period, TREE reported one permit deviation. In a letter dated May 9, 2017, NHDES requested that TREE perform formaldehyde emissions testing on the LFG-fired engines. TREE performed testing on November 7-8, 2017, and the results were unable to demonstrate compliance with Env-A 1400. TREE submitted its Initial Permit Deviation Notification on December 12, 2017, and a written notification December 22, 2017. Based on the results of the emissions testing, TREE prepared an alternative compliance demonstration pursuant to Env-A 1405.06 for formaldehyde emissions based on operating a maximum of two engines at any one time. The alternative compliance demonstration was approved by NHDES on November 2, 2018. Prior to and after the issuance of Temporary Permit TP-0239, TREE maintained records that demonstrated compliance with this alternative compliance demonstration.

X. Other Findings

TREE has installed sulfur treatment for the LFG going to the engine & turbine plants. To accomplish this, TREE relocated two sulfur treatment tanks previously used to treat the LFG going to UNH. In addition, TREE is in the process of upgrading sulfur treatment for the LFG received by UNH.

TREE has upgraded its Leachate Treatment Facility (LTF) by converting a sequencing batch reactor into an equalization basin and adding two membrane biological reactors with a total design treatment capacity of 300,000 gallons per day. Due to the fact that the LTF emits less than 1,000 lb/year of all regulated air pollutants, it meets the definition of an insignificant activity pursuant to Env-A 609.04. Ammonia is a Regulated Toxic Air Pollutant (RTAP) as defined in Env-A 1400. TREE demonstrated compliance with Env-A 1400 for ammonia and all other RTAP emissions based on potential uncontrolled rates.

The new TREE garage, “The Rochester Hauling Company Maintenance Garage,” is under construction. The garage will be heated with natural gas using radiant heating.


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TREE operates a CAT XQ125-3304 diesel fired emergency generator at its Material Recovery Facility. The generator has operated a total of 22 hours over the last five years, and is listed as a portable generator in the insignificant activities table. During the on-site inspection, TREE stated that the emergency generator resided at the same location for more than 12 consecutive months. The emergency generator no longer meets the definition of a portable unit, and on August 6, 2019, TREE submitted a temporary permit application that included a request to permit the CAT XQ125-3304 diesel fired generator as an emission unit. The application recognizes the unit as a stationary emergency generator subject to the same management and operating practices as emergency generator EU07.

On August 2, 2019, TREE submitted operation and maintenance logs for Flares #2 and #5 to NHDES. The revised monthly daily operating logs for each flare now include maintenance activities that were previously retained as paper records in office files located elsewhere on-site. TREE stated the facility will now maintain monthly daily operation and maintenance logs as a means to achieve a more formal compilation of these records.

XI. Enforcement History and Status During the evaluation period, NHDES did not issue any enforcement actions against TREE.

XII. Compliance Assistance, Recommendations and Corrective Actions During the inspection, TREE completed the following corrective actions:

As noted in the findings of Table 6, Item 12; on August 2, 2019, TREE submitted calibration records of the MASS-tron II mass flow transmitter to NHDES. NHDES recommends that all future landfill gas flow, pressure and temperature monitoring devices be calibrated following manufacturer’s recommended procedures at least once annually or in a manner and/or frequency approved by NHDES.

NHDES recommends that TREE explore the Energy Efficiency Incentive Program at www.nhsaves.com. For major renovations and end of life replacement of electrical devices, up to 75% of the incremental cost to install high efficient equipment is covered. The retrofit program offers incentives up to 50% of the installed cost to replace older equipment with new, energy efficient equipment. In addition, TREE can receive email notifications of rule changes by subscribing to E-News found at the following link:

https://secure.campaigner.com/CSB/Public/Form.aspx?fid=1600070

https://secure.campaigner.com/CSB/Public/Form.aspx?fid=1600070


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Report Prepared By Michael Camacho

Title Compliance Assessment Engineer

Signed

the state of new hampshire department of …solar turbines model: centaur 40 serial no. 3826c52 1997...

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