DAQ-2024-011908

1

DAQC-1206-24
Site ID 11977 (B4)
MEMORANDUM

TO: STACK TEST FILE – TRANS-JORDAN CITIES – Landfill Generation Facility

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: December 5, 2024

SUBJECT: Location: 1047 South Bacchus Highway, South Jordan, Salt Lake County, UT
Contact: Summer Hitchens, 515-604-1784
Tester: Montrose Air Quality Services, Cheyney Guymon, 801-794-2950
Source: Landfill Gas Generator Engines #1 - #3
FRS ID#: UT0000004903500535
Permit# : Title V operating permit 3500535004, dated July 21, 2020, last revised
January 12, 2023
Subject: Review of Pretest Protocol received November 22, 2024
On November 22, 2024, the DAQ received a protocol for emissions testing of the Trans-Jordan Landfill
Generator Engines #1 - #3 located in South Jordan, Salt Lake County, UT. Stack emissions testing will be
performed on January 14-15, 2025, to determine compliance with Title V operating permit Conditions,
II.B.3.a and II.B.3.c for VOC, CO, and NOx emissions.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3A used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 7E used to determine NOx emissions: OK
6. RM 10 used to determine CO emissions: OK
7. RM 25A used to determine total gaseous VOC emissions: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Stack testing protocol received November 22, 2024.
* - / $ - - $ )
Source Test Protocol for 2fJ25 Compliance
Emissions Testing
Three (3) Caterpillar 352OC Engine/Generators
Trans-Jordan Landfill
LO473 South Bacchus Highway
South Jordan, UT 84OO9
Prepared For:
Trans-Jordan Landfill
L0473 South Bacchus Highway
South Jordan, UT 84009
Prepared By:
Montrose Air Quality Selvices, LLC
6823 South 3600 West
Spanish Fork, UT 84660
For Submission To:
Utah Depaftment of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GPO81AS-O478O1-PP-932
Proposed Test Dates: January 14th and 15th, 2025
Submittal Date: November 2o, 2024
lfifrn or.PnRrMENT oF
E NV I R Q NU-E-N rAlguall r,Y
DtvtstoN oF AIR OI,ALITY
M MONTROSE
Review and Ceftification
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7O36-O4.
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Signature:
Name:
November 20,2024
Reporting QC Specialist III
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7O36-O4.
Slgnature:
Name:
? rli--L^rI. ;'\ \rr--, t-^..,r',November 20,2024
Beckie Hawkins Title:District Manager
Joby Dunnlire
2of81 GP081AS-047801-PP-932
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Table of Contents
Section Page
1.0 Introduction........ ...................5
1.1 Summary of Test Program ............... 5
t.2 Applicable Regulations and Emission Limits .......7
1.3 Key Personnel.......,... ......8
2.0 Plant and Sampling Location Descriptions.......... ......10
2.1 Proces Description, Operation, and Control Equipment.............. .......10
2.2 Flue Gas Sampling Locations ...........10
2.3 Operating Conditions and Process Data...... ......10
2.4 Plant Safety ....10
2.4.1 Safety Responsibilities..... ......11
2.4.2 Safety Program and Requirements .........L2
3.0 Sampling and Analytical Procedures .........13
3.1 Test Methods............ .....13
3.1.1 EPA Method 1.............. .........13
3.1.2 EPA Method 2............. ..........13
3.1.3 EPA Methods 3/3A........ ........L4
3.1.4 EPA Method 4....,........ ..........14
3.1.5 EPA Methods 3A,7E, and 10 .................14
3.1.7 EPA Method 25A......... ..........16
4.0 Quality Assurance and Reporting........... .................L7
4.L QA Audits. ......L7
4.2 Quality Control Procedures ..............17
4.2,L Equipment Inspection and Maintenance .................17
4.2.2 Audit Samples .......L7
4.3 Data Analysis and Validation ...........L7
4.4 Sample Identlfication and Custody ..................18
4.5 Quality Statement ..........18
4.6 Reporting .......18
4.5.1 Example Report Format .........19
4.6.2 Example Presentation of Test Resu|ts.............. .......19
3of81 GP08 1AS-04780 1-PP-932
List of Appendices
A Supporting Information,............. ...........21
A.1 UDEQ Permits ...............22
A.2 Accreditation Information......... .....63
r\S" Field Work Safety P1an......... ....,,...........67
List of Tables
1-1 Summary of Test Program and Proposed Schedule ............. .....5
l-2 Reporting Units and Emission Limits ........ 6
1-3 Test Personnel and Responsibilities.......,.. ..,............7
2-L Sampling Locations .....'..........8
4-L Example Emissions Results..... ...'...........20
List of Figures
3-1 US EPA Methods L, 2, and 4 Sampling Traln ....... '....13
3-2 US EPA Methods 3A, 7E, tO, and 25A Sampling Train........ ..'....15
4-1 Typical Report Format ............19
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I4of81cP081AS-04780 1-PP-932
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1.O Introduction
1.1 Summary of Test Program
Trans-Jordan Landflll contracted Montrose Air Quality Seruices, LLC (Montrose) to pedorm a
compliance emissions test program on sources listed in Table 1-1 at their facility located in
South Jordan, Utah.
The tests are being conducted to determine compliance with the applicable emission limits
listed in Sections II.B.3.a and II.B.3.c of the facility's Title V Air Quality Operating Permit
No. 3500535004, issued by the Utah Department of Environmental Quality (UDEQ). The
UDEQ also issued Approval Order (AO) DAQE-AN119770Ot2-22 for this facility.
The specific objectives are to:
Determine the concentrations of NOx, CO, and VOC in emissions from the
exhaust of Landfill Gas Engine #1.
Determine the concentrations of NOx, CO, and VOC in emissions from the
exhaust of Landfill Gas Engine #2.
Determine the concentrations of NOx, CO, and VOC in emissions from the
exhaust of Landfill Gas Engine #3.
Conduct the test program with a focus on safety.
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final repoft. A summary of the test program and proposed schedule is
presented in Table 1-1.
Table 1-1
Summary of Test Program and Proposed Schedulel
rThe test schedule is subject to change, based on process oPeratlon and avallablllty.
4.7E. LO,25A
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To simplify this test plan, a list of Units and Abbreviations is lncluded in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
1.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits, which are
taken from the Title V operating permit are presented in Table 1-2.
Table 1-2
Reporting Units and Emission Limits
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Landfill Gas
Englne #1
L.97
2.0
5.0
1.0
II.B.3.a
NSPS
II.B.3.c
II.B.3.c
NOx
co
voc
lb/hr
g/HP-hr
g/HP-hr
s/HP-hr
Landfill Gas
Engine #2
NOx
co
voc
lblhr
glHP-hr
glHP-hr
9/HP-hr
L.97
z.o
5.0
1.0
II.B.3.a
NSPS
II.B.3.c
II.B.3.c
II,B.3.A
NSPS
II.B.3.c
II.B.3.c
Landfill Gas
Engine #3
NOx
co
voc
lb/hr
g/HP-hr
g/HP-hr
g/HP-hr
L.97
2.0
s.0
1.0
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1.3 Key Personnel
A llst of project pafticipants is included below:
Facility Information
Source Location:Trans-Jordan Landfill
Generation Facility
L0473 South Bacchus Highway
South Jordan, UT 84009
Summer Hitchens
Environmental Compliance Specialist
5L7-604-L784
S u m mer. H itchens@ed lenerov. com
Utah Depaftment of Environmental Quality
Harold Burge
385-306-6509
Telephone:
Telephone:
Testlng Company Informatlon
Testing Flrm: Montrose Air Quality Services, LLC
Contact: Beckie Hawkins Cheyney Guymon
Title: District Manager Field Project Manager
Telephone: 8OL-372-7049 80L-794'295O
Email: [e-mail] [e-mail]
Table 1-3 details the roles and responsibilities of the test team.
Table l-3
Test Perconne! and Responsibilities
Agency Informatlon
Regulatory Agency:
Faclllty lnterface, test crew coordlnatlon
Preparatlon, support
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2.O Plant and Sampling Location Descriptions
2.1 Process Description, Operation, and Control
Equipment
Trans-Jordan Landfill generation facility is located at L0473 South Bacchus Highway, South
Jordan, Utah 84009. Trans-Jordan Cities operates the Trans-Jordan Landfill, a municipal
solid waste (MSW) landfil! source located in Salt Lake County, Utah. The facility accepts
municipal and commercial solid waste. Three (3) 2,250 horsepower Caterpillar 3520C landfill
gas fired generator engines (Landfill Gas Engines #t, #2, and #3) are installed to burn
landfill gas emissions. All three generators are equipped with air to fuel ratio controllers
(AFRC).
2.2 Flue Gas Sampling Locations
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Locations
Sample locations are verified in the fleld to conform to EPA Method 1. Acceptable ryclonic
flow conditions are confirmed prior to testing using EPA Method 1, Section 11.4.
2.3 Operating Conditions and Process Data
Emission tests are performed while the sources/units and air pollution control devices are
operating at representative conditions. As per Title V Operating Permit #3500535004,
5II.8.3.a.1(f), "The production rate during all compliance testing shall be no less than 90o/o
of the maximum production achieved in the previous three (3) years."
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
. Engine load, brake horsepower (bhp) or kilowatts (kW)
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Volumetric Flow Rate:
16 (8/port)*36/*2.8
Volumetric Flow Rate:
15 (8/port)*36/-2.8
Volumetric Flow Rate:
16 (8/port)*361-2.8
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2.4 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.4.1 Safety Responsibilities
Plannlng
. Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any pollcies or procedures that will affect our work.
. We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed.
. The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
. Montrose will provide a list of equipment being brought to the slte, lf required
by the client.
Project Day
. Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate.
. Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
pafticipate.
. Montrose will provide equipment that can interface with the cllent utllitles
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection.
. We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area.
. As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tlght.
o Safe sampling platforms.
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o Safe access to the platforms and test ports, including any scaffolding or
man lifts.
o Sufficient utilities to perform all necessary testing.
o A diesel generator will provide power as requested by site manager.
. Montrose will use the client communication system, as directed, in case of
plant or project emergency.
. Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
. Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site.
. Montrose will clean up our work area to the same condition as it was prior to
our arrival.
. We wlll ensure that all utlllties, connectlon polnts or equlpment have been
returned to the pre-project condltion or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.4.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an lllness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
. All regulatory required policies/procedures and training for OSHA, EPA and
FMCSA
. Medical monitoring, as necessary
. Use of Personal Protective Equipment (PPE) and chemical detection equipment
. Hazard communication
. Pre-test and daily toolbox meetings
. Continued evaluation of work and potential hazards
o Near-miss and incident reporting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix "S".
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3.O Sampling and Analytical Procedures
3,1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1,1 EPA Method 1, Sample and Velocity Traverses for Stationary
Sources
EPA Method 1 is used to assure that representative measurements of volumetric flow rate
are obtained by dividing the cross-section of the stack or duct into equal areas, and then
tocating a traverse point withln each of the equal areas. Acceptable sample locations must
be located at least two stack or duct equivalent diameters downstream from a flow
dlsturbance and one-half equivalent diameter upstream from a flow disturbance.
3.L.2 EPA Method 2, Determination of Stack Gas Velocity and
Volumetric Flow Rate (Type S Pitot Tube)
EPA Method 2 is used to measure the gas velocity using an S-type pitot tube connected to a
pressure measurement device, and to measure the gas temperature using a calibrated
thermocouple connected to a thermocouple indicator. Typically, Type S (Stausscheibe) pitot
tubes conforming to the geometric specifications in the test method are used, along with an
inclined manometer. The measurements are made at traverse points specified by EPA
Method 1. The molecular weight of the gas stream is determined from lndependent
measurements of Oz, COz, and moisture. The stack gas volumetrlc flow rate is calculated
using the measured average velocity head, the area of the duct at the measurement plane,
the measured average temperature, the measured duct static pressure, the molecular
weight of the gas stream, and the measured molsture.
Pertinent information regarding the peformance of the method ls presented below:
. Method Options:
o S-type pitot tube coefficient is 0.84
o Shortridge multimeter may be used to measure velocity
o A dry molecular weight of 30.0 lbllb-mole may be used to calculate gas
volumetric flow rate for combustion sources.
The sampling apparatus is detailed in Figure 3-1.
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3.1.3 EPA Method 4, Determination of Moisture Content in Stilck
Gas
EPA Method 4 is used to measure the moisture content of gas streams. Gas is sampled
through a probe and impinger train. Moisture is removed using a series of pre-weighed
impingers containing methodology-specific liquids and silica gel immersed in an ice water
bath. The impingers are weighed after each run to determine the percent moisture.
Pertinent information regarding the performance of the method is presented below:
o Condensed water is measured gravimetrically.
o Since it is theoretically impossible for measured moisture to be higher
than psychrometric moisture, the psychrometric moisture is also
calculated, and the lower moisture value is used in the calculations.
o Minimum Required Sample Volume: 21 scf
o Method Options:
o EPA Approved Alternative Method 009 (ALT-009) is used as an
alternative to a two-point post-test meter box calibration. This
procedure uses a calculatlon to check the meter box calibration
factor rather than requiring a physical post-test meter box
calibration using a standard dry gas meter. The average calculated
meter box percent (o/o) error must result in a percent error within
*5olo of Y. If not, a full calibration is performed, and the results are
presented using the Y factor that yields the highest emissions.
o EPA Approved Alternative Method 011 (ALT-011) is used as an
alternative to the EPA Method 2 two-point thermocouple
calibration. This procedure involves a single-point in-field check
using a reference thermometer to confirm that the thermocouple
system is operating properly. The temperatures of the
thermocouple and reference thermometers shall agree to within ,12
oF.
The typical sampling system is detailed in Figure 3-1.
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I12 of 81 GP08 lAS-047801-PP-932
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Figure 3-1
US EPA Methods 1,2, and 4 Sampling Traln
SAMPLE LINE
tTYPE'S'
PITOT
MANOMETER .--.-+,- VACUUM*- uNE
THERMOCOUPLEJl
i,ANOMETER _--D
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3.L,4 EPA Methods 3A, 7E, and 1O, Determination of Oxygen,
Carbon Dioxide, Nitrogen Oxides, and Carbon Monoxide
Concentrations in Emissions from Stationary Sources
(Instrumental Analyzer Procedures)
Concentrations of Oz, COz, NOxT ?nd CO are measured simultaneously using EPA Methods
3A, 7E, and 10, which are instrumental test methods. Conditioned gas is sent to a series of
analyzers to measure the gaseous emission concentrations. The performance requirements
of the method must be met to validate the data.
Pertinent lnformation regarding the performance of the method is presented below:
. A dry extractive sampling system may be used to report emissions on a dry
basis.
. Sampllng may be performed using a dilution probe.
. A paramagnetic analyzer is used to measure Oz.
o A nondispersive infrared analyzer is used to measure COz.
. A chemiluminescent analyzer is used to measure NOx.
. A gas fllter correlatlon nondlspersive lnfrared analyzer is used to measure CO.
o The alternative NOx converter efficienry test described in EPA Method 7E
Section 16.2 may be used .
. Minimum Required Sample Duration: 60 minutes
The typical sampling system is detailed in Figure 3-2.
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I14 of 81 GP08 1AS-047 80L-PP-932
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Figure 3-2
US EPA Methods 3At 7E, 1O, and 25A Sampllng Train
Edr$t
S.mgb / C.h.don Glr
Erh!6t
/ C.[b6llon Gr.
Elhad
E Erd
E)dEult
Exhtui
'mEMmffiMMv[E
IAf, ROTAIEIERwffiMM
ALIBRATION
GAS UNE
SIGNAL
.-------{>
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Iffi
ltrl5^milf lfMffiffiEfff mvAE
sgwuL
-t
.{>
Irgw[
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'IS
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HEATED
SAMPLE
LINE
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3.1.6 EPA Method 25A, Determination of Total Gaseous Organic
Concentration Using a Flame Ionization Analyzer
EPA Method 25A is an instrumental test method used to measure the concentrations of THC
and methane in the stack gas. A gas sample is extracted from the source through a heated
sample line and glass fiber filter to a flame ionization analyzer (FIA). Results are reported as
volume concentration equivalents of the calibration gas or as carbon equivalents.
Pertinent information regarding the peformance of the method is presented below:
. Results are reported in terms of propane (C3H8).
. Span value is -0-100 ppmvw
. Minimum Required Sample Duration: 60 minutes
. Methane concentrations will be determined using an FID equipped with a real time
methane cutter and the results may be subtracted from the THC results to results in
a total non-methane hydrocarbon (TNMHC) or VOC result. The methane cutter will
be verified using methane and ethane calibration gases, per manufacturer check
procedure.
The typical sampling system is detailed as part of the EPA Methods 3A, 7E, and 10 sampling
system in Figure 3-2.
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4.O Quality Assurance and Reporting
4.L QA Audits
Montrose has instituted a rigorous QA/QC program for its alr quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This ptogram ensures that the emissions
data we repoft are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
wilt also perform the sampling, sample recovery, storage, and shlpping. Approved contract
laboratories may peform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows intemal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.L Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4,2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose convets the raw field, laboratory, and process data to reporting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report. The"Standard Conditions"forthis project are29.92
inches of mercury and 68 oF.
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4.4 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is superuised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented timits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.L and 12.10. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.5 Repofting
Montrose will prepare a final repoft to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and ceftified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facitity or appropriate regulatory agenry (upon customer approval) within
60 days of the completion of the field work. The report will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.5.1 Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
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Figure 4-1
Typlcal Repoft Format
Cover Page
Geftification of Repoil
Table of Contents
Sectlon
1.0 Introduction
2.0 Plant and Sampling Location Descriptions
3.0 Sampllng and Analytical Procedures
4.0 Test Discussion and Results
5.0 lntemal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility Process Data
C Laboratory Analysis Data
D Quality Assurance/Quallty Control
E Regulatory Informatlon
4.5.2 Example Presentation of Test Results
Table 4-1 presents the typlcal tabular format that ls used to summarlze the results in the
final source test repoft. Separate tables will outline the results for each target analyte and
compare them to their respective emissions limits.
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Table 4-1
Example Emlsslons Results
Date xx xx xx
Tlme xx xx xx
Sampllng & Flue Gas Parameters
sample duratlon, mlnutes XX xx xx xx
Oz, o/o volume dry xx xx xx xx
COz, o/o volume dry xx xx xx xx
flue gas temperature, oF xx xx xx xx
moisture content, o/o volume xx xx xx xx
volumetric flow rate, dscfm xx xx xx xx
Nitrogen Oxides (NOx) Emissions
ppmvd xx xx xx xx
lblhr XX xx XX xx
g/bhp-hr
Carbon Monoxlde (CO) Emlsslons
ppmvd XX xx xx xx
lblhr xx xx xx xx
g/bhp-hr
Volatlle Organlc Compounde (VOG)
ppmvw as CsHe XX xx xx xx
ppmvd as CsHe xx xx XX xx
ppmvd as CrHs XX xx xx xx
lblhr as CsHe xx xx xx xx
g/bhp-hr as CsHa xx xx xx xx
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Appendix A
Supporting Information
Appendix A.1
UDEQ Permits
GP08 1AS-04780 1-PP-932
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State of Utah
CARYHERBERT
Govctnor
SPENCERJ.@X
Lieulemnt Govcmor
Department of
Environmental Quality
AIur Mrthcson
Ereativc Direcar
DTVISION OF AIRQUALITY
Br!ca,C.Bitd
Permitted Location:
Trans-Jordan Landfill
10473 South Baoohus Highwoy
South Jordan LIf M095-0610
tt977
Title V Operating Permit
PERIIf,IT I\UMBER: 3 5 0053 5003
DATE OF PERMIT: June 30, 2015
Date of Last Revision: Juno 30, 2015
This Operating Permit is issued to, and applies to the following:
Name of Permittee:
Trans-Jordan Cities
10473 S. Bacchus Highway (U-l I l)
PO Box 95610
South Jordan Lrf 84095-0610
UTM coondinates: 410,879 m Easting 4,490,492 m Northing
SIC code: 4953 (Refuse Systems)
UTAH AIR QUALITY BOARD
I 50 North 1950 Wcat . Srlt Lako City, UT
Maillng Addrcss: P.O. Box I'14E20 . Sdt Lakc City, UT 84 I 144820
Tclcphonc (E0l) 5364000 . Fax (801) 536-{099 . T.D,D. (E0l) 536414
w.dcq.uoh.gov
Priotcd oo l$96 rcoyctcd prpcr
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ENFORCEABLE DATES AND TIMELINES
The following dates or timeframes are referenced in
Section I: General Provisions of this permit.
Annual Certification Due: April 15 and on that date of every calendar year that this permit is
in force.
Renewal application due: December 30,2019
Permit expiration date: June 30, 2020
Definition of "prompt": written notification within 14 days.
Trans-Jordan Cities operates the Trans-Jordan Landfill, a municipal solid waste (MSW) landfill source located
in Salt Lake County, Utah. The facility accepts municipal and commercial solid waste. Class I Sanitary
Landfill with a 10.5 million Mg capacity. Opened in 1958, lateral expansion in 1997198. The landfill is a Title
V area source.
TransJordan Landfill is subject to:
New Source Performance Standards (NSPS) under 40 CFR Part 60, Subparts A - General Provisions
New Source Performance Standards (NSPS) under 40 CFR Part 60, Subpart WWW - Standards of
Performance for Municipal Solid Waste Landfills
New Source Performance Standards (NSPS) under 40 CFR Part 60, Subpart JJJJ - Standards of
Performance for Stationary Spark Ignition Internal Combustion Engines
National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart A - Ceneral Provisions
National Emissions Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR Part 61, Subpart A -
General Provisions
National Emission Standards for Asbestos: Standards for Active Waste Disposal Sites, 40 CFR 61,
Subpart M
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Titlc V Opcrating Permit #3500535003
GP08 1AS-04780 1- PP-932
Project OPP0119770005
OPERATING PERMIT HISTORY
PermiUActivitv Date Issued Recorded Changes
Title V renewal application
(Project #OPPOl 19770004)
6t30t20ts Renewal of Title V Permit and Incorporation of
requirements from 40 CFR Part 60, Subpart JJJJ.
Title V renewal application
(Project #OPP0 I I 9770003)
2lt7t300e Renewal of Title V Permit and Incorporation of
requirements from new AO (DAQE-AN0 l 1 9770006-08)
for installation of three landfill gas fueled engines.
Title V initial application
(Proiect #OPP01 19770001)
5t2v2002 Title V lssued
Projecl OPP0119770005 Title V Operating Pcrmit #3500535003
GP08 1AS-047801-PP-932
Table of Contents
ENFORCEABLE DATES AND TIMELINES..............
ABSTRACT
OPERATING PER]VIIT HISTORY..
SECTION I: GENERAL PROVISIONS............
Administrative Permit Amendments ..'....'...... 9
Title IV and Other, More Stringent Requirements................ .......'....... I I
SECTION II: SPECIAL PROVISIONS...........-.......... 12
Emission Unit(s) Permitted to Discharge Air Contaminants. .........,. .-.-.................... 12
Conditions on Perrnitted Source (Source-wide)...,............... .-...'.'.'." 12
Conditions on Municipal Solid Waste LandfiIl.................. ..'.'."""' 14
Conditions on Landfili Gas Engines. ......"""..."""""'25
Conditions on Landfill Gas Flare..... """'27
SECTION III: PERMIT SHIELD.
A permit shield was not granted for any specific requirements ."""""' 28
SECTION IV: ACID RAIN PROVISIONS.................. ...."""'."""""" 28
This source is not subject to Title IV. This section is not app1icab1e............... """"'28
REVTEWER COMMENTS....................
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Issued under authority of Utah Code Ann. Section 19-2-104 and 19-2-109.1, and in accordance with Utah
Administrative Code Rt07-415 Operating Permit Requirements.
All definitions, terms and abbreviations used in this permit conform to those used in Utah Administrative Code
R307-l0l and R307-415 (Rules), and 40 Code of Federal Regulations (CFR), except as otherwise defined in this
permit. Unless noted otherwise, references cited in the permit conditions refer to the Rules.
Where a permit condition in Section I, General Provisions, partially recites or summarizes an applicable rule, the
full text of the applicable portion of the rule shall govern interpretations of the requirements of the rule. In the
case of a conflict between the Rules and the permit terms and conditions of Section [[, Special Provisions, the
permit terms and conditions of Section ll shall govern except as noted in Provision I.M, Permit Shield.
SECTION I: GENERAL PROVISIONS
Federal Enforcement.
All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-4 I 5-6b)
Permitted Activity(ies).
Except as provided in R307-415-7b(l), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)
Duty to Comply.
The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6Xa))
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to hatt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6Xb))
The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also fumish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confi dentialiry. (R307-4 I 5-6a(6)(e))
This permit may be modified, revoked, reopened, and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation and
reissuance, or termination, or of a notification of planned changes or anticipated
noncompliance shall not stay any permit condition, except as provided under R307-415-
7f(1) for minor permit modifications. (R307-415-6a(6Xc))
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Permit Expiration and Renewal.
This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))
Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1Xc))
An application for renewal submitted after the due date listed in 1.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-a l5-5a(5))
Permit expiration terminates the permittee's right to operate unless a tirnely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision LE,
Application Shield) and R307-415-5a(l)(c) (see also Provision I.D.2). (R307-al5-7c(2))
Application Shield.
If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit ienewal application. ln such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))
Severability.
In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))
Permit Fee.
The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-a1s-6a(7))
The emission fee shall be due on October I ofeach calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))
No Property Rights.
This permit does not convey any property rights ofany sort, or any exclusive privilege.
(R307-41 s-6a(6Xd))
Revision Exception.
No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-al5-6a(8))
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'l'itle V Opersting Permit #3500535003
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Inspection and Entry.
Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:
Enter upon the permittee's premises where the sotrce is located or emissions related activity
is conducted, or where records are kept under the conditions of this permit. (R307-415-
6c(2)(a))
Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit. (R307-41 5-6c(2Xb))
Inspect at reasonable times any facilities, equipment (including monitoring and air pollution
controt equipment), practice, or operation regulated or required under this permit. (R307-
415-6c(2Xc))
Sample or monitor at reasonable times substances or parameters for the purpose of assuring
compliance with this permit or applicable requirements. (R307'415-6c(2Xd))
Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2Xe))
Certification.
Any application form, report, or compliance certification submitted pursuant to this permit
shall contain ceftification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief fonned after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307415-5d)
Compliance Certlfication.
Permittee shall submit to the Director an annual compliance certification, certiSing
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-
6c(s))
The identification of each term or condition of this permit that is the basis of the
certification;
The identification of the methods or other means used by the permittee for determining the
compliance status with each term and condition during the certification period. Such
methods and other means shall include, at a minimum, the monitoring and related
recordkeeping and reporting requirements in this permit. If necessary, the permittee also
shall identify any other material information that must be included in the certification to
comply with section I l3(cX2) of the Acq which prohibits knowingly making a false
ceftifi cation or omitting material information;
The status of compliance with the terms and conditions of the permit for the period covered
by the certification, including whether compliance during the period was continuous or
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intermittent. The certification shall be based on the method or means desigrrated in
Provision l.L.l.b. The cefiification shall identify each deviation and take it into account in
the compliance certification. The certification shall also identifu as possible exceptions to
compliance any periods during which compliance is required and in which an excursion or
exceedance as defined under 40 CFR Part 64 occurred; and
Such other facts as the Director may require to determine the compliance status.
The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-41 5-
6c(sXd))
Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129
Permit Shield.
Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:
Such applicable requirements are included and are specifically identified in this permit, or
(R307-4ls-6(lXa))
Those requirements not applicable to the source are specifically identified and listed in this
permit. (R307-41 5-6f(1 )(b))
Nothing in this permit shall alter or affect any of the following:
The emergency provisions of Utah Code Ann. Section l9-l-202 and Section 19-2-112, and
the provisions of the CAA Section 303. (R307-a15-6f(3)(a)
The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(9) and Section l9-2-l l0 prior to
or at the time of issuance of this permit. (R307-415-6f(3xb)
The applicable requirements of the Acid Rain Program, consistent with the CAA Section
408(a). (R307-4 1 s-6(3Xc))
The ability of the Director to obtain information from the source under Utah Code Ann.
Section lg-z-L}O,and the ability of the EPA to obtain information from the source under
the CAA Section I14. (R307-41s-6f(3xd))
Emergency Provision.
An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or oPerator error. (R307-al5-6g(1))
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An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:
An emergency occurred and the permittee can identif, the causes of the emergency. (R307-
a 1 s-6g(3)(a))
The permitted facility was at the time being properly operated. (R307-415-69(3Xb))
During the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards, or other requirements in this
permit. (R307-4 I 5-6g(3)(c))
The permittee submitted notice of the emergency to the Director within two working days
of the time when emission limitations were exceeded due to the emergency. This notice
must contain a description of the emergency, any steps taken to mitigate emissions, and
conective actions taken. This notice fulfills the requirement of Provision LS.2.c below.
(R3 07-4 I s-6c(3xd)
In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden ofproof. (R307-al5-6g(a))
This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-al5-6g(5))
Operational Flexibility.
Operational flexibility is governed by R307'415-7d(l).
Off-permit Changes.
Off-permit changes are governed by R307-415'7d(2).
Administrative Permit Amendments.
Administrative permit amendments are governed by R307-415-7e'
Permit Modificatlons.
Permit modifications are govemed by R307-415-7f.
Records and Reporting.
Records.
The records of all required moni'toring data and support information shall be retained by the
permittee for a period of at least five years from the date of the monitoring sample,
measurement, repoft, or application. Support information includes all calibration and
maintenance records, all original strip-charts or appropriate recordings for continuous
monitoring instrumentation, and copies of all reports required by this permit. (R307-415-
6a(3Xb)(ii))
For all monitoring requirements described in Section II, Special Provisions, the source shall
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record the following information, where applicable: (R307-a 1 5-6a(3XbXi))
The date, place as defined in this permit, and time of sampling or measurement.
The date analyses were performed.
The company or entity that performed the analyses.
The analytical techniques or methods used.
The results ofsuch analyses.
The operating conditions as existing at the time of sampling or measurement.
Additional record keeping requirements, if any, are described in Section II, Special
Provisions.
Reports.
Monitoring reports shall be submitted to the Director every six months, or more frequently
if specifred in Section II. All instances of deviation from permit requirements shall be
clearly identifi ed in the reports. (R307-4 I 5-6a(3)(c)(i))
All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official
in accordance with Provision I.K of this permit. (R307-415-6a(3Xc)(i)
The Director shall be notified promptly of any deviations from permit requirements
inoluding thosc attributable to upset conditions as defined in this pernrit, the probable cause
of such deviations, and any corrective actions or preventative measures taken. Prompt, as
used in this condition, shall be defined as written notification within the number of days
shown under "Enforceable Dates and Timelines" at the front of this permit. Deviations
from permit requirements due to breakdowns shall be reported in accordance with the
provisions of R307- I 07. (R3 07-4 1 5-6a(3 )(c)(ii))
Notification Addresses.
All reports, notifications, or other submissions required by this permit to be submitted to the
Director are to be sent to the following address or to such other address as may be required
by the Director:
Utah Division of Air Quatity
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: 80 l-536-4000
All reports, notifications or other submissions required by this pennit to be submitted to the
EPA should be sent to one of the following addresses or to such other address as may be
required by the Director:
For annual compliance certifi cations:
Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
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Denver, CO 80202-1129
For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:
Environmental Protection Agency, Region VIII
Office of Partnerships & Regulatory Assistance Air & Radiation Program (mail code 8P-
AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]
Reopening for Cause.
A permit shall be reopened and revised under any of the following circumstances:
New applicable requirements become applicable to the permittee and there is a remaining
permit term of three or more years. No such reopening is required if the effective date of
the requirement is later than the date on which this permit is due to expire, unless the terms
and conditions of this permit have been extended pursuant to R307-415-7c(3), application
shield. (R307-41s-7g(l)(a)
The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or
conditions of this permit. (R307-41 5-7g(1Xc))
EPA or the Director determines that this permit must be revised or revoked to assure
compl iance with appl icable requirements. (R307-4 I 5-7g( 1 Xd))
Additional applicable requirements are to become effective before the renewal date of this
permit and are in conflict with existing permit conditions. (R307-415-7g(1Xe))
Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit. (R307-415'
7e(lXb))
Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-a I 5-79(2))
Inventory Requirements.
An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307- I 50)
Title IV and Other, More Strlngent Requirements
Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1Xb))
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SECTION II: SPECIAL PROVISIONS
Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-4 I s4(3Xa) and R307-4 I 5-4(4))
Permitted Source (Source-wide)
Municipal Solid Waste Landfill
Class I Sanitary Landfill with a 10.5 million Mg capacity. Opened in 1958, lateral expansion in
1997198. NSPS WWW and NESHAP M applies to this unit.
Landfill Gas Engines
Three 1,600 Kw landfill gas only fired engines.
Landfill Gas Flsre
Flare burns gas collected from the landfill collection system, candle stick type flare
Requirements and Limitations
The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:
Conditions on Permittc<l Source (Source-wide).
Condition:
Visible emissions caused by fugitive dust shall not exceed l0o/o at the property boundary, and2DYo onsite.
There is no exception during periods when wind speeds exceed 25 miles per hour. [Authority granted
under (R3 07-3 09-3 ( I )); condition ori ginated in R3 07-3 09-5 l.
Monitoring:
In lieu of monitoring via visible emissions observations, adherence to the most recently approved
fugitive dust control plan shall be maintained in order to demonstrate that appropriate measures
are being implemented to control fugitive dust.
Recordkeeping:
Records of measures taken to control fugitive dust shall be maintained to demonstrate adherence
to the most recently approved fugitive dust control plan. If wind speeds are measured to establish
an exception from the above visible emissions limits, records of those measurements shall be
maintained. Records shall be maintained as described in Provision I.S.1 of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
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Condition:
Visible emissions shall be no greater than 20 percent opacity, unless otherwise specified in this permit.
[Authority granted under R307-201-3; condition originated in R307-201-3].
Monitoring:
A visual opacity survey of each affected emission unit shall be performed on a quarterly basis, by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9, or
other EPA-approved testing method, as acceptable to the Director. If visible emissions other than
steam are observed from an emission unit, an opacity determination of that emission unit shall be
performed by a certified observer within 24 hours of the initial survey. The opacity
determination shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA-approved testing method, as acceptable to the Director, for point sources, and in accordance
with 58 FR 61640 Method 203C for fugitive emission sources.
Recordkeeping:
The permittee shall record the date of each visual opacity survey and keep a list of the emission
points checked during the visual opacity survey. The permittee shall also keep a log of the
following information for each observed visual emission: date and time visual emissions
observed, emission point location and description, time and date of opacity survey, and percent
opacity. The records required by this provision and all data required by 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director shall be
maintained in accordance with Provision I.S.l of this perrnit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Sulfur content of any fuel oil combusted shall be no greater than 0.85 lb/lr4MBtu heat input. [Authority
granted under R30?-203-11' condition originated in R307-203-l l.
Monitoring:
For each delivery of oil, the permittee shall either:
(l) Determine the fuel sulfur content expressed as lb/MMBtu in accordance with the methods of
the American Society for Testing Materials (ASTM) and Equation l; or
(2) Inspect documentation provided by the vendor that has demonstrated compliance with (l)
above, or indirectly demonstrates compliance with this provision.
Equation
Fuel Sulfur Content, lb/MMBtu = (Weight percent sulfur/l00) x Density (lb/gal)] / [(gross
heating value (Btu/gal)) x (l MMBtu/I,000,000 Btu)1.
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Recordkeeping:
Results of monitoring shall be maintained as described in Provision I.S.1 of this pennit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Records shall be maintained of the material (salt, crushed slag, or sand) applied to the roads by the
permitted source. If the permittee applies crushed slag sand, or salt that is less than 92% sodium chloride
to roads they must demonstrate to the Board that the material applied has no more PM ro emission than
salt which is at least 92% sodium chloride. [Authority granted under R307-307; condition originated in
R307-3071.
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
The following records shall be maintained as outlined in Provision LS.l of this pennit:
For Salt - the quantity applied, and the percent by weight of insoluble solids in the salt.
For Sand or Crushed Slag - the quantity applied and the percent by weight of finc matcrial which
passes the number 200 sieve in a standard gradation analysis.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condilions on Municipal Solitl Wnsle Lnndfill.
Condition:
The permittee shall comply with all applicable requirements in 40 CFR 60, Subpart WWW'New Source
Performance Standards (NSPS) Standards of Performance for Municipal Solid Waste Landfills. The
permittee shall comply with the applicable General Provisions in 40 CFR 60, Subpart A'
(a) The permittee shall calculate a nonmethane organic compounds (NMOC) emission rate for the landfill
using the procedures specified in monitoring. The NMOC emission rate shall be recalculated
annually, except as provided in paragraph (bxl)(D ofreporting.
(l) If the calculated NMOC emission rate is less than 50 megagrams per year, the permittee shall:
(i) Submit an annual emission report to the Director, except as provided for in Section I1.B.2.a.3
Reporting and paragraph (bXlxi) of reporting; and
(ii) Recalculate the NMOC emission rate annually using the procedures specified in (a) of
Title V Operating Pcrmit #3500535003
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monitoring until such time as the calculated NMOC emission rate is equal to or greater than
50 megagrams per year, or the landfill is closed.
(A) lf the NMOC emission rate, upon recalculation required in paragraph (aXlXii), is equal
to or greater than 50 megagrams per year, the permittee shall install a collection and
control system in compliance with 40 CFR 60.752(bX2).
(B) If the landfill is permanently closed, a closure notification shall be submitted to the
Director as provided for in (d) of reporting.
(2) If the calculated NMOC emission rate is equal to or greater than 50 megagrams per year, the
permittee shall:
(i) Submit a collection and control system design plan prepared by a professional engineer to the
Director within 1 year:
(A) The collection and control system as described in the plan shall meet the design
requirements of paragraph 40 CFR 60.752(bX2Xii),
(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 40 CFR 60.753 through 60.758 proposed by the
permittee.
(C) The collection and control system design plan shall either confonn with specifications for
active collection systems in 40 CFR 60.759 or include a demonstration to the Director's
satisfaction of the sufliciency of the alternative provisions to 40 CFR 60.759.
(ii) The permittee shall install a collection and control system capable of meeting emissions
standards in 40 CFR 60.750 within 30 months of the date when the landfill has an emission
rate of NMOC of 50 megagrams per year or more.
(b) When the MSW landfill is closed, the permittee is no longer subject to the requirement to maintain an
operating permit under 40 CFR 70 for the landfill if the landfill is not otherwise subject to the
requirements of either 40 CFR 70 and if either of the following conditions are met:
(l) The landfill was never subject to the requirement for a control system under paragraph (a)(2); or
(2) The permittee meets the conditions for control system removal specified in 40 CFR
60.7s2(b)(2)(v).
[Authority granted under 40 CFR 60.750(d); condition originated in 40 CFR 60.750]
Monitoring:
The permittee shall monitor the NMOC emission rate by using the equations in (a) and following
the three tier process outlined in (b), (c), and (d):
(a) The permittee shall calculate the NMOC emission rate using either the equation provided
in paragraph (a)(l) or the equation provided in paragraph (aX2). Both equations may be
used if the actual year to year solid waste acceptance rate is known, as specified in
paragraph (a)(l) for part ofthe life ofthe landfill and the actual year to year solid waste
acccptancc ratc is unknown, as spccificd in paragraph (a)(2), for part ofthe life ofthe
landfill. The values to be used in both equations are 0.02 per year for k, 170 cubic meters
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per megagram for LO, and 4,000 parts per million by volume as hexane for the CNMOC.
For either (aX I ) or (a)(2) below, the mass of non-degradable solid waste may be
subtracted from the total mass of solid waste in a particular section of the landfill when
calculating the value for Mi if documentation of the nature and amount of such wastes is
maintained.
(l) The following equation shall be used if the actual year to year solid waste acceptance
rate is known.
Mxrraoc = Sum (2kL, Mi (e-k'i)(CNr,,les)(3.6x10-e)) of i through n
where,
MNuoc =Total NMOC emission rate from the landfill, megagrams per year
k=methane generation rate constant, per year
Lo=methane generation potential, cubic meters per megagram solid waste
M; :mass of solid waste in the ith section, megagrams
ti =age ofthe ith section, years
CNuoc =concentration of NMOC, parts per million by volume as hexane
3.6 x l0-e=conversion factor
(2) The following altemative equation shall be used if incremental(tenths of one year)
solid waste acceptance rate is known.
Muuoc : Sum (k L" (Mi /1O)e-ktij (CNruoc) (3.6x104)) of i through n
Where:i = I year time increment
n : (year of the calculation) - (initial year of waste acceptance)j: 0,1 year time increment
Muuoc = Total NMOC emission rate from the landfill, megagrams Per year
k = methane generation rate constant, per year
Lo = nrethanc generation potential, cubic nteters per tnegaBrflm solid waste
M; = lfloss ot'solid w:utc in the irn year, tnegagranls
tij = age of the je section of waste mass M, acccptcd itt tlte i"' year (dccinral years,
e.g., 3.2 years)
CNruroc = concentration of NMOC, parts per million by volume as hexane
3.6 x l0-e=conversion factor
(b) Tier 1. The permittee shall compare the calculated NMOC mass emission rate to the
standard of 50 megagrams per year.
(l) If the NMOC emission rate calculated in (a) is less than 50 megagrams per year, then
the permittee shall submit an emission rate report as provided in paragraph (b)(1) 9f
reporting, and shall recalculate the NMOC mass emission rate annually as required
under paragraph (a)(l) ofthis condition.
(2) If the calculated NMOC emission rate is equal to or greater than 50 megagrams per
year, tlren the permittee shall either comply with paragraph (aX2) of this condition, or
determine a site specific NMOC concentration and recalculate the NMOC emission
rate using the procedures provided in (c).
(c) Tier 2.The permittee shall determine the site-specific NMOC concentration using the
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following sampling procedure.
The permittee shall installat least two sample probes per hectare of landfill surface that
has retained waste for at least 2 yearc.lf the landfitl is larger than 25 hectares in area,
only 50 samples are required. The sample probes should be located to avoid known areas
of non-degradable solid waste.
The permittee shall collect and analyze one sample of landfill gas from each probe to
determine the NMOC concentration using 40 CFR 60, Appendix A Method 25 ot 25C.
Method 18 of Appendix A may be used to analyze the samples collected by the Method
25 or 25C sampling procedure. Taking composite samples from different probes into a
single canister is allowed; however, equal sample volumes must be taken from each
probe. For each composite sample, the sampling rate, collection times, beginning and
ending canister vacuums, or alternative volume measurements must be recorded to verify
that composite volumes are equal. Composite sample volumes should not be less than
one Iiter unless evidence can be provided to substantiate the accuracy of smaller
volumes. Terminate compositing before the canister approaches ambient pressure where
measurement accuracy diminishes.
If using Method 18, the permittee must identify all compounds in the sample and, as a
minimum, test for those compounds published in the most recent Compilation of Air
Pollutant Ernission Factors (AP 42), minus carbon monoxide, hydrogen sulfide, and
mercury. As a minimum, the instrument must be calibrated for each of the compounds on
the list.
Convert the concentration of each Method l8 compound to CNMOC as hexane by
multiplying by the ratio of its carbon atoms divided by six. [f more than the required
ruumber of sanrples are taken, allsamples must be used in the analysis. The permittee
must divide the NMOC concentration from 40 CFR 60 Appendix A Method 25 or 25C
by six to convert from CNMOC as carbon to CNMOC as hexane.
If the landfill has an active or passive gas removal system in place, Method 25 or 25C
samples may be collected from these systems instead of surface probes provided the
removal system can be shown to provide sampling as representative as the two sampling
probe per hectare requirement. For active collection systems, samples may be collected
from the common header pipe before the gas moving or condensate removal equipment.
For these systems, a minimum of three samples must be collected from the header pipe.
( I ) The permittee shall recalculate the NMOC mass emission rate using the equations
provided in (a)(l) or (aX2) of this monitoring section, using the average NMOC
concentration from the collected samples instead of the default value in the equations
provided in (a).
(2) If the resulting mass emission rate calculated using the site specific NMOC
concentration is equal to or greater than 50 megagrams per year' then the permittee
shall either comply with paragraph (a)(2) of this condition, or determine the site
specific methane generation rate constant and recalculate the NMOC emission rate
using the site specific methane generation rate using the procedure specified in (d).
(3) If the resulting NMOC mass emission rate is less than 50 megagrams per year, the
permittee shall submit a periodic estimate of the emission rate report as provided in
paragraph (b)(l) of reporting and retest the site specific NMOC concentration every 5
years using the methods specified in monitoring.
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(d) Tier 3. The site specific methane generation rate constant shall be determined using the
procedures provided in 40 CFR 60, Appendix A, Method 2E . The permittee shall
estimate the NMOC mass emission rate using equations in (a) and using a site specific
methane generation rate constant k, and the site specific NMOC concentration as
determined in (c) instead of the default values provided in (a). The pennittee shall
compare the resulting NMOC mass emission rate to the standard of 50 megagrams per
year.
( I ) If the NMOC mass emission rate as calculated using the site specific methane
generation rate and concentration of NMOC is equal to or greater than 50
megagrams per year, the permittee shall comply with paragraph (aX2) of this
condition.
(2) lf the NMOC mass emission rate is less than 50 megagrams per year, then the
permittee shall submit a periodic emission rate report as provided in paragraph
(b)(l) of reporting and shall recalculate the NMOC mass emission rate annually, as
provided in paragraph (a)(1) ofreporting using the equations in (a)(l) or (a)(2) and
using the site specific methane generation rate constant and NMOC concentration
obtained in (c). The calculation of the methane generation rate constant is performed
only once, and the value obtained from this test shall be used in all subsequent
annual NMOC emission rate calculations.
Recordkeeping:
(a) Except as provided in paragraph (aX2Xi)(B) of this condition when subject to (a) of this
condition, the permittee shall keep for at least 5 years up to date, readily accessible, on site
records of the design capacity report which triggered (a) of this condition, the current amotlnt
of soli<l waste in place, ard tlre year by year waste acceptallce mte. Off site records may be
maintained if they are retrievable within 4 hours. Either paper copy or electronic formats are
acceptable.
(b) Results of monitoring shall also be maintained in accordance with provision 1.S.1 of this
permit.
Reporting:
Except as provided in paragraph (a)(2XiXB) of this condition,
(a) An amended design capacity report shall be submitted to the Director providing notification of
any increase in the design capacity ofthe landfill, whether the increase results from an increase
in ihe permified area or depth of the landfill, a change in the operating procedures, or any other
means which results in an increase in the maximum design capacity of the landfill. The
amended design capacity report shall be submitted within 90 days of the earliest of the
following events:
( I ) the issuance of an amended operating permit;
(2) submittal of application for a solid waste permit under R3 1 5'3 1 0; or
(3) the change in operating procedures which will result in an increase in design capacity.
(b) The permittee shall submit an NMOC emission rate report to the Director initially and
annually thereafter, except as provided for in paragraph (b)(1Xi). The Director may request
such additional information as may be necessary to verify the reported NMOC emission rate.
(l) The NMOC emission rate repoft shall contain an annual or 5 year estimate of the NMOC
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emission rate calculated using the formula and procedures provided in monitoring.
(i) If the estimated NMOC emission rate as reported in the annual report to the Director is
less than 50 megagrams per year in each of the next 5 consecutive years, the permiftee
may elect to submit an estimate of the NMOC emission rate for the next 5 year period
in lieu of the annual report. This estimate shall include the current amount of solid
waste in place and the estimated waste acceptance rate for each year of the 5 years for
which an NMOC emission rate is estimated. All data and calculations upon which this
estimate is based shall be provided to the Director. This estimate shall be revised at least
once every 5 years. If the actual waste acceptance'rate exceeds the estimated waste
acceptance rate in any year reported in the 5 year estimate, a revised 5 year estimate
shall be subrnitted to the Director. The revised estimate shall cover the 5 year period
beginning with the year in which the actual waste acceptance rate exceeded the
estimated waste acceptance rate.
(2) The NMOC emission rate report shall include allthe data, calculations, sample reports and
measurements used to estimate the annual or 5 year emissions.
(c) Each permittee subject to the provisions of paragraph (a)(2)(i) of this condition shall submit a
collection and control system design plan to the Director within I year of the first report
required under (b) in which the emission rate equals or exceeds 50 megagrams per year,
except as follows:
(l) If the permittee elects to recalculate the NMOC emission rate after Tier 2 NMOC
sampling and analysis as provided in (c) of monitoring and the resulting rate is less than
50 megagrams per year, annual periodic reporting shall be resumed, using the Tier 2
determined site specific NMOC concentration, until the calculated emission rate is equal
to or greater than 50 megagrams pcr year or thc lnndfill is closed. Tltc revised NMOC
emission rate report, with the recalculated emission rate based on NMOC sampling and
analysis, shall be submitted within 180 days of the first calculated exceedance of 50
megagrams per year.
(2) lf the permittee elects to recalculate the NMOC emission rate after determining a site
specific methane generation rate constant (k), as provided in Tier 3 in (d) of monitoring,
and the resulting NMOC emission rate is less than 50 Milyr, annual periodic reporting
shall be resumed. The resulting site specific methane generation rate constant (k) shalt be
used in the emission rate calculation until such time as the emissions rate calculation
results in an exceedance. The revised NMOC emission rate report based on the
provisions of (d) of monitoring and the resulting site specific methane generation rate
constant (k) shall be submitted to the Director within I year of the first calculated
emission rate exceeding 50 megagrams per year.
(d) Each permittee of a landfillshall submit a closure repon to the Director within 30 days of
waste acceptance cessation. The Director may request additional information as may be
necessary to verify that permanent closure has taken place in accordance with the
requirements of 40 CFR 258.60. lf a closure report has been submitted to the Director, no
additional wastes may be placed into the landfill without filing a notification of
modification as described under 40 CFR 60.7(a)( ).
(e) The permittee shall notify the Director of the awarding of contracts for the construction of
the collection and control system or the order to purchase components for the system.
This notification shall be submitted within l8 months after reporting an NMOC emission
equal to or greater than 50 megagrBms per year.
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(0 The permittee shall also comply with the reporting requirements of Section I of this
permit.
Condition:
The permittee shall comply with all applicable requirements in 40 CFR 61, Subpart M - National
Emission Standards for Asbestos. The permittee shall comply with the applicable General Provisions in
40CFR6l SubpartA-GeneralProvisions. [Authoritygrantedunder40CFR6l.l40-61.157;
condition originated in 40 CFR 61 Subpart Ml
The permittee shall meet one of the following requirements for all asbestos disposal operations at the
landfill:
(a) there shall be no visible emissions to the outside air from any active waste disposal site where
asbestos-containing waste material has been deposited,
(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 material that has been deposited at the site during the
operating day or previous Z4-hour period shall:
(l) be covered with at least 15 centimeters (6 inches) of compacted non-asbestos-containing
material, or
(2) be covered with a resinous or petroleum-based dust suppression agent that effectively binds dust
and controls wind erosion. Such an agent shall be used in the manner and frequency
recommended for the particular dust by the dust suppression agent manufacturer to achieve and
maintain dust control. Other equally effective dust suppression agents may be used upon prior
approval by the Director. For purposes o[ this paragraph, any used, speut, ol' other waste oil is
not considered a dust suppression agent.
(c) use an alternative emissions control method that has received prior written approval by the U.S.
Environmental Protection Agency (USEPA) according to the procedures described in 40 CFR
6 I . 1 a9(c)(2). [Authority granted under 40 CFR 6 I . I 54; condition originated in 40 CFR 6 I . I 54].
Monitoring:
lf the permittee chooses to comply with the no visible emissions provisions of this condition, a
visual opacity observation ofeach active asbestos disposal site shall be perfonned on a daily basis
in accordance with 58 FR 61640 Method 203C.
lf the permittee chooses to comply with the daily cover provisions of this condition, a visual
inspection of the site(s) where asbestos containing waste material is deposited shall be conducted
on the day of deposit to ensure that asbestos has been covered in accordance to (b)( I ) above.
Intermittent visual inspections at least once per week will be performed in order to verify
integrity of cover material, and compliance with this condition.
Titlc V Operating Permit #3500535003
G P08 1AS-047 801-PP -932
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Recordkeeping:
If the permittee chooses to comply with the no visible emissions provisions of this condition, a
log of the visual opacity observations shall be maintained as described in Provision S.1 in Section
I of this permit. All data required by 40 CFR 60, Appendix A, Method 9 or 58 FR 61640,
Method 203C shall also be maintained as described in Provision S.l in Section I of this permit.
tf the permittee chooses to comply with the daily cover provisions of this condition, results of the
day ofdeposit and subsequent weekly visual inspections shall be recorded in a log and
maintained as described in Provision S.l in Section I of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Condition:
Unless a natural banier adequately deters access by the general public, the permittee shall comply with
one of the following:
(a) the fencing and warning sign requirements of 40 CFR 61.154 (b), 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 material that has been deposited at the site during the
operating day or previous 24-hour period shall be covered with at least l5 centimeters (6 inches) of
compacted non-asbestos-containing material. [Authority granted under 40 CFR 61.154; condition
originated in 40 CFR 61.1541.
Monitoring:
If the permittee chooses to comply with the fencing and warning sign provisions of this condition,
a visual inspection ofthe property line including all entrances to the site and/or sections ofthe
site where asbestos containing waste material is deposited shall be conducted quarterly to verify
compliance with the fencing and waming sign requirements of 40 CFR 61.154 (b)
If the permittee chooses to comply with the daily cover provisions of this condition, a visual
inspection of the site(s) where asbestos containing waste material is deposited shall be conducted
the day of deposit, and weekly thereafter to verify compliance with this condition.
Recordkeeping:
Results of all inspections shall be recorded in a log and maintained as described in Provision S.l
in Section I of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
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Condition:
The perrnittee shall maintain waste shipment records of all asbestos-containing waste material received.
In addition to routine shipment-tracking information, the waste shipment records shall document
instances of improperly enclosed or uncovered waste, or any asbestos-containing waste material not
sealed in leak-tight containers. [Authority $anled under 40 CFR 61.154 (e); condition originated in 40
cFR 6l.rs4l.
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
For all asbestos-containing waste material received, the permittee shall maintain waste shipment
records, using a form similar to that shown in 40 CFR 61.149, Figure 4, and include the following
information:
(i) The name, address, and telephone number of the waste generator. Waste generator is defined
as any owner or operator ofa source covered by 40 CFR 61, Subpart M whose act or process
produces asbestos-containing waste material.
(ii) The name, address, and telephone number of the transpoter(s).
(iii) The quantity of the asbestos-containing waste material in cubic meters (cubic yards).
(iv) The presence ofany improperly enclosed or uncovered waste, or any asbestos-containing
waste material not sealed in leak+ight containers.
(v) The date of the receipt.
AllRecords shall be maintained as described in Provisions I.S.l of this permit.
Reporting:
As soon as possible and no longer than 30 days after receipt ofthe asbestos-containing waste
material, the permittee shall send a copy of the signed waste shipment record to the waste
generator. The permittee shall report in writing to the Director, by the following working day, the
presence of a significant amount (either nine (9) or more drums/bamels (35 gallon each) or of
seventeen (17) or more plastic bags) of improperly enclosed or uncovered waste and submit a
copy of the waste shipment record along with the report.
Upon discovering a discrepancy between the quantity of waste designated on the waste shipment
records and the quantity actually received, the permittee shall attempt to reconcile the
discrepancy with the waste generator. If the discrepancy is not resolved within l5 days after
receiving the waste, the permittee shall immediately submit a written report to the Director
describing the discrepancy and attempts to reconcile it, and submit a copy of the waste shipment
record along with the report. The permittee shall retain a copy of all records and reports required
by this condition for at least 5 years. All reports shall be in accordance with Provision I.S.2 of
this permit.
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Condition:
The permittee shall maintain, until closure, records of the location, depth and area, and quantity in cubic
meters (cubic yards) of asbestos-containing waste material within the disposal site on a map or diagram of
the disposal area. [Authority granted under 40 CFR 61 . I 54 (f); condition originated in 40 CFR 6 I . I 54].
Monitoring:
Records required for this permit condition will serve as monitoring.
Recordkeeping:
Maintain, records of the location, depth and area, and quantity in cubic meters (cubic yards) of
asbestos-containing waste material within the disposal site on a map or diagram of the disposal
area. All Records shall be maintained as described in Provisions I.S.l of this permit
Reporting:
Notifi the Director in writing at least 45 days prior to excavating or otherwise disturbing any
asbestos-containing waste material that has been deposited at a waste disposal site and is covered.
If the excavation will begin on a date other than the one contained in the original notice, notice of
the new start date must be provided to the Director at least l0 working days before excavation
begins and in no event shall excavation begin earlier than the date specified in the original
notification. lnclude the following information in the notice:
( I ) Scheduled starting and completion dates.
(2) 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. lf deemed necessary,
the Director may require changes in the emission control procedures to be used.
(4) Location of any temporary storage site and the final disposal site.
All reports shall be in accordance with Provision I.S'2 of this permit.
Condition:
Upon closure of an asbestos-containing waste disposal site, the permittee shall submit a copy of records
of asbestos waste disposal locations and quantities and shall:
(a) Comply with one of the following:
(l) Either discharge no visible emissions to the outside air from an inactive asbestos'containing
waste disposal site or
(2) Cover the asbestos-containing waste material with at least l5 centimeters (6 inches) of
compacted non-asbestos containing material, and grow and maintain a cover of vegetation on the
area adequate to prevent exposure ofthe asbestos-containing waste material. In desert areas
where vegetation would be diflicult to maintain, at least 8 additional centimeters (3 inches) of
well-graded, non-asbestos crushed rock may be placed on top of the final cover instead of
vegetation and maintaincd to prcvcnt cmissions; or
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(3) 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
(4) For inactive waste disposal sites for asbestos tailings, a resinous or petroleum-based dust
suppression agent that effectively binds dust to control surface air emissions may be used instead
of the methods in paragraphs (a) (l), (2), and (3) of this section. Use the agent in the manner and
frequency recommended for the particular asbestos tailings by the manufacturer of the dust
suppression agent to achieve and maintain dust control. Obtain prior written approval of USEPA
to use other equally effective dust suppression agents. For purposes ofthis paragraph, any used,
spent, or other waste oil is not considered a dust suppression agent.
Unless a natural banier adequately deters access by the general public, install and maintain warning
signs and fencing as follows, or comply with paragraph (a)(2) or (aX3) of this condition:
(l) Display warning signs at all entrances and at intervals of 100 m (328 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 was deposited. The warning signs must:
(i) Be posted in such a manner and location that a person can easily read the legend; and
(ii) Conform to the requirements for 51 cmx36 cm (20"x 14") upright format signs specified in29
CFR 1910.145(dX4) and this paragraph; and
(iii) Display the following legend in the lower panel with letter sizes and styles of a visibility at
least equal to those specified in this paragraph.
Legend Notation
Asbestos Waste Disoosal Site 2.5 cm (l inch) Sans Serif, Gothic or Block
Do Not Create Dust 1.9 cm (3/4 inch) Sans Serif, Gothic or Block
Breathing Asbestos is
Hazardous to Your Health l4 Point Gothic
Spacing between any two lines must be at least equal to the height of the upper of the two lines.
(2) Fence the perimeter of the site in a manner adequate to deter access by the general public.
(3) When requesting a determination on whether a natural barrier adequately deters public access,
supply information enabling the Administrator to determine whether a fence or a natural banier
adequately deters access by the general public.
(c) In lieu of complying with the requirements of paragraph (a) or (b) of this condition, the permittee
may use an altiinative control method that has received prior approval of the USEPA' [Authority
granted under 40 CFR 6l . 154 (g); condition originated in 40 CFR 6l .l 5 11.
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II.B.3
II.B.3.a
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IVlonitoring:
A visual inspection of each closed site where asbestos containing waste material is deposited
shall be conducted quarterly to verify compliance with all the requirements of 40 CFR 6l.l5l.
Recordkeeping:
Results of all inspections shall be recorded in a log and maintained as described in Provision S.1
in Section I of this permit.
Reporting:
(a) Notifu the Director in writing at least 45 days prior to excavating or otherwise disturbing any
asbestos-containing waste material that has been deposited at a waste disposal site and is
covered. Ifthe excavation will begin on a date other than the one contained in the original
notice, notice of the new start date must be provided to the Director at least l0 working days
before excavation begins and in no event shall excavation begin earlier than the date specified
in the original notification. Include the following information in the notice:
(l) Scheduled starting and completion dates.
(2) 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. If deemed
necessary, the Director may require changes in the emission control procedures to be used.
(4) Location of any temporary storage site and the final disposal site.
(b) Within 60 days of a site becoming inactive and after the effective date of this subpart, record,
in accordance with State law, a notation on the deed to the facility property and on any other
instrument that would normally be examined during a title search; this notation will in
perpetuity notify any potential purchaser ofthe properly that:
(1) The land has been used for the disposal of asbestos-containing waste material;
(2) The survey plot and record of the location and quantity of asbestos-containing waste
disposed of within the disposal site required in 40 CFR 6l.154(0 have been filed with the
USEPA; and
(3) The site is subject to 40 CFR 61, Subpart M.
Conditions on Landfill Gas Eneines.
Condition:
Emissions of NO* shall be no greater than 1.97 lb/hr.[Authority granted under R307-a01-8(lXa) [BACT];
condition originated in DAQE-AN0l 19770006-081.
Monitoring:
Stack testing shall be performed as specified here:
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I1.B.3.a.3
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(a) Frequency. The source shall be tested every 8760 hours ofoperation or tluee years based
on the date of the last stack test. (40CFR Part 60, Subpart JIJJ 60.4243(bx2xii))
(b) Notification. At least 30 days before the test, the source shall notify the Director of the
date, time, and place oftesting and provide a copy ofthe test protocol. The source shall
attend a pretest conference if determined necessary by the Director.
(c) The emission sample point shall be designed to conform to the requirements of 40 CFR
60, Appendix A, Method l. ln addition, Occupational Safety and Health Administration
(OSHA) approved access shall be provided to the test location. (R307-165-2)
(d) Methods to be used:
(l) To determine stack volumetric flow rate - 40 CFR 60, Appendix A, Method 2.
(2) To test for NO, emissions - 40 CFR 60, Appendix A, Method 7 ,7 A, 78,7C,7D, or
7F.,
(e) Calculations. To determine mass emission rates (g/kw-hr) the pollutant concentration as
deterrnined by the appropriate methods above shall be multiplied by the volurnetric flow
rate, divided by the engine's power output during the test and multiplied by any
necessary conversion factors.
(f) Production Rate During Testing. The production rate during all compliance testing shall
be no less than 907o of the maximum production achieved in the previous three (3) years.
Recordkeeping:
Results of monitoring shall be maintained in accordance with Provision LS.l of this permit.
Reporting:
The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. There are no additional repo(ing requirements for this provision except those
specified in Section I of this permit.
Condition:
The permittee shall comply with all applicable requirements in 40 CFR 60, Subpart JJJJ - Standards for
Stationary Spark Ignition Intemal Combustion Engines. The engines shall meet the applicable
requirements of 60.4233 Table 1, Emission limit of carbon monoxide (CO) 5.0 g/HP-hr and volatile
organic compounds (VOC) of 1.0 g/HP-hr. For purposes of this subpart, when calculating emissions of
VOC, emissions of formaldehyde should not be included. The permittee shall comply with60.4234,
60.4243(a)(2),60.4243(a)(2xiiD, 60.4243(b)(1) and (2), 60.a2$G) and 60.4246. The perrnittee shall
comply with the applicable general provisions in 40 CFR 60.1 thru 60.19 as identified in Table 3 of 40
CFR 60, Subpart JJJJ 60.4246.
[Authority granted under 40 CFR 60.4230; condition originated in 40 CFR 60 Subpart JJJJ]
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II.B.4
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11.B.4.a.2
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Monitoring:
The permittee shall perform all applicable monitoring required in 40 CFR 60.a2a3@)(2Xii) and
(iii),60.4243(bx2xii), 60.42a4@) and (f). The permittee shall certify, in the annual compliance
statement required in Section I of this permit, its compliance status with the applicable
requirements of 40 CFR 60, Subpart JJJJ,
Recordkeeping:
The permittee shall maintain all records required in 60.4243(a)(l),60.4243(aX2Xi) thru (iii),
60.4243(b)(2XiD, 60.4245(a)(1) thru (4). There are no additional recordkeeping requirements
except as outlined in Provision LS.l of this permit.
Reporting:
The permittee shall submit all reports required in60.4245(c) and (d), if applicable. There are no
additional reporting requirements except as outlined in Section I of this permit.
Condltions on Landfill Gas Flare.
Condition:
The landfill gas flare shall only be operated for control of landfiU gas emissions and only during periods
when one or more of the landfill gas generator engines are offline. During the periods that the generators
are offline, all potential emissions of landfill gas shall be routed through the landfill gas flare for control
prior to being released to the atmosphere.[Authority granted under 40 CFR 60 Subpart A, 40 CFR 60.18;
condition originated in DAQE-AN 197 7 002-061.
Monitoring:
Records shall serve as monitoring.
Recordkeeping:
Records shall be kept for all times when the landfill gas flare is in operation. Records shall
include date and time.
Reporting:
There are no additional reporting requirements other than those found in section 1 of this permit.
Conditlon:
The flare shall be operated perthe general provisions of40 CFR 60.18(c) through (f). The flare shall be
operated with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2
consecutive hours. The flare shall be operated with a flame present at all times. [Authority granted under
R307-40 I -8 [BACT] ; condition originated in DAQE-AN0 1 I 9770006-081
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Ii.B.4.b.1
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III.A
II.C
II.D
IV.A This source is not subject to Title IV. This section is not applicable.
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Monitoring:
A determination of flare visible emissions shall be conducted monthly. The observer must
understand the variables that affect the plume and factors that affect selection ofthe observation
location as described in Method 22 section 2.3. A thermocouple or any other equivalent device
shall be used to monitor the presence of a pilot flame in the flare.
Recordkeeping:
Results of monitoring shall be maintained in accordance with Provision I.S.l of this permit.
Reporting:
There are no reporting requirements for this provision except those specified in Section I of this
permit.
Emissions Trading
(R307-415-6a(10)
Not applicable to this source.
Alternative Operating Scena rios.
(rc07-als-6a(9))
Not applicable to this source.
SECTION III: PERMIT SHIELD
A permit shield was not granted for any specilic requirements.
SECTION IV: ACID RAIN PROVISIONS
Project OPP0119770005
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This operating permit incorporates all applicable requirements contained in the following documents:
I Incorporates DA QE-AN0 I I 9770006-08 dated September 23, 2008
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Comment on an item originating in 40 CFR 64 regarding Permitted Source (Source-wide)
Compliance Assurance Monitoring Applicability: CAM applicability has been evaluated.
There are no CAM requirements in this permit. [Last updated February 23,20157
Comment on an item originating in the 2004 Title V permit: Salting and Sanding Condition:
The 2004 condition implied that the Landfill roads are exempt from the 92% minimum
sodium chloride when applying salt to roads (R307-30'l-2). However, the rule states "any
salt applied to roads in Salt Lake, Davis, or Utah Counties must be at least 92% sodium
chloride [R307-307-2]. The permittee may demonstrate to the Director that the material
applied has no more PMl0 emissions than the 92% sodium chloride [R307-307-l(a)] OR
they may vacuum sweep arterial roadways as outlined in R307-307-3(1Xb)." There was
an error in reading the rule for an exclusion of salting requirements if a road was not an
"arterial roadway." The salting requirements of R307-307-l and R307-307-l(a) still must
be upheld. [Last updated February 23,2015)
Comment on an item originating in DAQE-AN0119770006-08 regarding Landfill Cas Engines
Stack installation parameters: Condition ILB.4.a of DAQE-AN01 1 9770006-08 requires
that the stacks shall vent vertically and be no less than 36 feet as measured from the base
of the stack. These are installation requirements and have been met and verified by
inspection. They are not being caried forward into the operating permit. [Last updated
February 23,2015)
Comment on an item originating in 40 CFR 60.154 regarding Municipal Solid Waste Landfill
Definition of Significant Amount for asbestos shipments received: A significant amount of
waste is hereby defined as one cubic meter of asbestos-containing waste material. Based
on EPA standard conversion factors for typical asbestos-waste containers, one cubic meter
of material is approximately equal to 9.8 drums or barrels (35 gallon each) or 17.4 plastic
bags. [Last updated February 23,2015]
Comment on an item originating in DAQE-ANO119770006-08 regarding Municipal Solid Waste
Landfill gas generators and WWW applicabitity: Trans-Jordan Landfill is voluntarily
installing landfill gas generators. NSPS subpart WWW is applicable but they are not
required to install or operate a gas collection and control system until the NMOC levels
have reached 50 Mg/yr. [Last updated February 23,2015]
Comment on an item originating in R307-205-5 regarding Municipal Solid Waste Landfill
Fugitive dust: The requirement to minimize fugitive dust in condition II.B.1,a of this
permit originates in R307-205-5. Although R307-l-4.5 (March 31,1992) is the current
Environmental Protection Agency (EPA)-approved State Implementation Plan (SIP)
version of the rule, R307-205-5 is as stringent and is cited as the authority for the
condition. [Last updated February 23,20151
Comment on an item originating in R307-415-4(3Xb) regarding Municipal Solid Waste Landfill
Title V requirements for area sources: In accordance with the referenced rule, because the
landfill is the emission unit that causes the pennittee to be subject to the operating permit
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program, only requirements applioable to the landfill have been included in the permit.
Any requirements applicable to emission units not directly related to the landfill have not
been included. [Last updated February 23,2015)
Comment on an item originating in Operating Permit regarding Cold Cleaning Unit
To remove a piece of equipment: The cold cleaning unit has been removed from the site.
Since it was not listed in the approval order so it has been removed from the operating
permit without an approval change. [Last updated February 23,2015]
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State of Utah
SPENCERJ. COX
Governor
DEIDRE TIENDERSON
Lieutenant Govemor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DTVISION OF AIR QUALITY
Bryce C. Bird
Director
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DAQE-ANI19770012-22
June24,2022
Jaren Scott
Trans-Jordan Cities
PO Box 95610
South Jordan, UT 84095-0610
j arenscott@transj ordan. org
Dear Mr. Scott:
Re: Approval Order:
Modification of Approval Order DAQE-ANI19770011-18 to Update Equipment and Potential-
to-Emit Emissions
Project Number: Nl 19770012
The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOt) received on May 3,
2021. Trans-Jordan Cities must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.
The project engineer for this action is Jake Ries, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper righrhand corner of this letter. No public comments were received
on this action.
Sincerely,
4aN
Bryce C. Bird
Director
BCB:JR:sa
cc: Salt Lake County Health Department
Dan Fagnant, EPA Region 8
Gail Fallon, EPA Region 8
195 North 1950 West. Salt Lakc City, UT
Mailing Address: P.O. Box 144820 . Salt Lako City, UT 841144820
Telephone [phone] . Fax (801) s364099. T.D.D. (801) 5364414
w.deq.utah.gov
Priqtcdon BY"drtF** GpoglAs-047goL-pp-932
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Department of Environmental Quality
Division of Air Quality
APPROVAL ORDER
DAQE-AFI119770012-22
Modification of Approval Order DAQE-AN119770011-18 to Update
Equipment and Potential-to-Emit Emissions
Prepared By
Jake Ries, Engineer
(38s) 306-6s30
[e-mail]
Issued to
Trans-Jordan Cities - Trans-Jordan Landfill
Issued On
June 24,2022
Issued By
"42NBryce C. Bird
Director
Division of Air Quality
GP08 1AS-047801-PP-932
TABLE OF CONTENTS
TITLE/SIGNATTIRE PAGE
GENERAL INT'ORMATION
CONTACT/LOCATION INFORMATION .......3
souRCE rNFORMATION........ ........................ 3
General Description .....................- 3
NSR Classification..... ...................3
Source Classification ............. .......3
Applicable Federal Standards '......3
Project Description ........................4
SLTMMARY OF EMISSIONS......... ...................4
SECTION I: GEI\ERAL PROYISIONS
SECTION II: PERMITTED EQIIIPMENT
SECTION II: SPECIAL PROYISIONS
PERMIT IIISTORY
ACROI{YMS
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Owner Name
Trans-Jordan Cities
Mailing Address
PO Box 95610
South Jordan, UT 840950610
Source Contact
Name Jaren Scott
Phone [phone]
Email j arenscott@hansj ordan. org
SIC code 4953 (Refuse Systems)
GEI\'ERAL INF'ORMATION
CONTACT/LOCATION INT'ORMATION
Source Name
Trans-Jordan Cities - Trans-Jordan Landfill
Physical Address
10473 South Bacchus Highway (Hwy 1l l)
South Jordan, UT 84009-6002
UTM Coordinates
410879 m Easting
M90492 mNorthing
Dahrm NAD27
UTMZone 72
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SOURCE INFORMATION
General Description
Trans-Jordan Cities (Trans-Jordan) owns and operates the Trans-Jordan Landfill in South Jordan. The
facility accepts municipal and commercial waste. Equipment on site consists of three landfill gas-fired
generator engines, one diesel-fired emergency generator engine, and one candlestick flare. Emissions are
from landfrll gas combustion and diesel combustion.
NSR Classification
Minor Modification at Major Source
Source Classification
Located in Norftern Wasatch Front O3 NAA, Salt Lake City UT PMz.s NAA, Salt Lake County SOz
NAA
Salt Lake County
Airs Source Size: A
Applicable Federal Standards
NSPS (Paxt 60), A: General Provisions
NSPS (Part 60), WWW: Standards of Performance for Municipal Solid Waste Landfills
NSPS (Part 60), IItr: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
NSPS (Part 60), JJJJ: Standards of Perforrnance for Stationary Spark Ignition Internal
Combustion Engines
NESHAP (Part 61), A: General Provisions
NESIIAP (Part 61), M: National Emission Standard for Asbestos
MACT (Part 63), 2277: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Intemal Combustion Engines
Title V (Paxt 70) Major Source
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DAQE-ANI19770012-22
Page 4
Project Description
Trans-Jordan has requested a modification to AO DAQE-ANI19770011-18, dated May 17,2018, to
replace the candlestick flare with an enclosed combustor flare, and to add a diesel-fired emergency
generator engine. All landfill gas that is not combusted by the on-site landfill gas-fired engines will be
routed to the new enclosed combustor flare. Facility-wide PTE was re-evaluated as part of this
modification based on the updated equipment list and operation. The following updates were made to the
AO:
1) Replace the bypass candlestick flare (previously II.A.5) with an enclosed combustor flare
(II.A.6).
2) Added one (l) 67[{F diesel-fned emergency generator engine (II.A.5).
3) Updated PTE to account for updated equipment.
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.
SECTION I: GEI{ERAL PROVISIONS
Criteria Pollutant Chanse ffPY)Total (TPY)
COz Equivalent 5954 30129.00
Carbon Monoxide 57.58 219.15
Nitrosen Oxides t7.37 43.22
Particulate Matter - PMro 3.93 11.91
Particulate Matter - PMz.s 3.93 11.91
Sulfur Dioxide 2.62 5.48
Volatile Orsanic Compounds 0.58 52.93
Hazardous Air Pollutant Chanse Obs/w)Total flbs/vr)
Formaldehvde (CAS #50000)0 19080
Generic HAPs (CAS #GI{APS)660 19180
Chanqe (TPY)Total (TPY)
Total HAPs 0.33 I 9.13
t.l All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
t.2 The limits set forth in this AO shall not be exceeded without prior approval. [](3074011
I.3 Tfodfiadons to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's replfsentative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307401-8]
57 of 81 GP08 1AS-047801-PP-932
DAQE-ANI19770012-22
Page 5
SECTION tr: PERMITTED EQIIIPMENT
THE APPROVED EOUIPMENT
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[5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution conhol 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 Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R3074014]
r.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-r07]
r.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-1s0]
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within l8 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307401-18]
tr.A.t Trans-Jordan Landlill
Lt.A.2 Generator #1
3520 Caterpillar Landfill Gas-Fired Generator
Rating: 22501lP
tr.A.3 Generator #2
3520 Caterpillar Landfill Gas-Fired Generator
Rating: 22501JP
u.4.4 Generator #3
3520 Cateryillar Landfill Gas-Fired Generator
Rating: 2250ID
I.I.A.5 Emergency Generator Engine
Rating: 67I{PFuel: Ultra Low Sulftr Diesel (ULSD)
tr.A.6 Enclosed Combustor FlareCapacity: 3,500 scfu
tr.A.7 MSW Landlill (designated ss Lsadfill)
Class I Sanitary LandErll with a 14.5 million Mg capacity. Opened in 1958, lateral expansion in
1997/98. NSPS WW-W andNESIIAP M applies to this unit.
tr.A.8 Gas Processing and Treatment Station
Dewatering tanls, gas compressors, gas coolers
58 of 81 GP08 1AS-047801-PP-932
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DAQE-ANI t97700t2-22
Page 6
tr.B
SECTION tr: SPECIAL PROVISIONS
REOT]IREMENTS AI\D LIMITATIONS
TI.B.1 Site'wide Req uirements
ll.IJ.l.a The owner/operator shall not allow visible emissions from the following emission units to exceed
the following values:
A. Fugitive dust - 10% at the properly boundary afi20% on-site
B. Enclosed Flare - No visible emissions
C. All other points - l0% opacity
[R307-309, R307401-8]
tr.B.1.a.1 Opacity observations of emissions from any stationary source on site shall be conducted
according to 40 CFR 60, Appendix A, Method 9. [R307401-8]
u.IJ.I.b The owner/operator shall meet all applicable requirements of 40 CFR 60 Subpart WWW -
Standards of Performance for Municipal Solid Waste Landfills and 40 CFR 62 Subpart OOO -
Federal Plan Requirements for Municipal Solid Waste Landfills That Commenced Constuction
On or Before JtrJy 17,2014 and Have Not Been Modified or Reconstructed Since July 17,2014.
[40 CFR 60 Subpart W-W'W, 40 CFR 62 Subpart OOO]
II.B.2 Flare Requirements[.t .2.a The owner/operator shall route excess landfill gas to the enclosed combustor flare when the
production of landfill gas exceeds the capacities of the generators or when at least one landfill
gas-fred generator is offline. [R307401-8]
l.lJ.3 Landfill Gas-Fired Generator Ensine Requirements
II.B.3.a The exhaust stack for each landfill gas-fired generator engine shall vent vertically unrestricted
with no obstruction to upward momentum at or beyond the opening of the stack. Stack height
shall be no less than 36 feet as measured from the base of the stack. [R307-401]
tr.B.3.b The owner/operator shall not allow NO* emissions from each landfill-gas fired generator to
exceed 1.97 lbs/hr. [R307401-8]
U.IJ.J.b.I Stack testing to show compliance with the emission limitations stated in the above condition
shall be performed as specified below:
Testing
Emissions Point
Compressor and Generator Engines
Pollutant
NO*
Frequency
#
A. Testing Frequency# Compliance test at least once every 8,760 hours ofoperation or once every tlree years,
whichever comes first. The Director may require testing at any time.
B. Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The source test protocol shall be approved by the Director
prior to performing the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest conference shall
be held, if directed by the Director.
59 of 81 GP081AS-047801-PP-932
DAQE-ANI19770012-22
PageT
60 of 81
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA testing methods as acceptable to the Director. An
O-cupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2, Method 19 or other EPA testing methods acceptable
to the Director.
NO*
40 CFR 60, Appendix A, Method 7,7A,7B,7C,7D or 7E, or other EPA testing methods
acceptable to the Director.
F. Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined
by the appropriate methods above shall be multiplied by the volumetric flow rate and any
necessary conversion factors deterrnined by the Director, to give the results in the
specified lnits of the emission limitation.
G. The owner/operator shall submit a copy of the results of the test to the Director within 60
days after the test has been completed.
H. New Source Operation
For a new sourbe/emission point, the combustion rate during all compliance testing shall
be no less that9}%o of the capacity listed in Section tr.A. If the maximum AO allowable
combustion rate has not been achieved at the time of the test, the following procedure
shall be followed:
1) Testing shall be at no less than9}% of the combustion rate achieved to date.
2) If the test is passed the new maximum allowable combustion rate shall be 1.10o/o
of the tested achieved rate, but not more than the maximum allowable
combustion rate. This new allowable maximum combustion rate shall remain in
effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher combustion rate when necessary.
Testing at no less than 90% ofthe higher rate shall be conducted. A new
maximum combustion rate (110% of the new rate) will then be allowed if the
test is successfrrl. This process may be repeated until the maximum AO
combustion rate is achieved.
I. For an existing source/emission point, the production rate during all compliance testing
shall be no less thang}o/o of the maximum production achieved in the previous three (3)
years.
[R307-150, R3074ol-8]
C.
D.
E.
II.IJ.4 EmergencY Ensine Requirements
II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per
calendar year during non-emergency situations. There is no time limit on the use of the engines
during emergencies. [40 CFR 60 Subpart 2277, R307401-8]
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Page 8
PERMIT HISTORY
This Approval Order shall supersede or will be based on the following documents:
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Supersedes
Is Derived From
Incorporates
Incorporates
Incorporates
AO DAQE-AN 1 1977001 1- I 8 dated le'day 17 , 2018
NOI dated May 3,2021
Additional Infonnation dated January 11,2022
Additional lnformation dated January 26,2022
Modeling Memo DAQE-MNI19770012-22 dated February 11,2022
tr.B.4.a.1 To detennine compliance, the owner/operator shall calculate a new total for each calendar year.
Records documenting the operation of the emergency engine shall be kept in a log and shall
include the following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage
[40 CFR 60 Subpart 7722, R307401-8]
n.8.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307401-8, 40 CFR 63 Subpart ZZZA
ll.Ir.4.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1,#2, or diesel fuel oil additives) as
fuel in each emergency engine. [R307401-8]
ll.u.4.b. t The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or less.
[R307401-8]
L.8.4.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307401-8]
61 of 81 G P08 1AS-047 80t -PP -932
DAQE-ANI19770012-22
Page 9
ACROI\I-YMS
The following lists commonly used acronyrns and associated translations as they apply to this document: I
Title 40 of the Code of Federal Regulations
Approval Order
Best Available Control Technology
Clean Air Act
Clean Air Act Amendments
Classification Data System (used by Environmental Protection Agency to classi$
sources by sizeltype)
Continuous emissions monitor
Continuous emissions monitoring system
Code of Federal Regulations
Continuous monitoring system
Carbon monoxide
Carbon Dioxide
Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
Continuous opacity monitor
Division of Air Quality
This is a document tracking code for internal Division of Air Quality use
Environmental Protection Agency
Fugitive dust control plan
Greenhouse Gas(es) --Tille 40 of the Code of Federal Regulations 52.21(bX49Xi)
Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
Hazardous air pollutant(s)
Intent to Approve
Potrnds per year
Maximum Achievable Control Technology
Million British Thermal Units
Nonattainment Area
National Ambient Air Quality Standards
National Emission Standards for Hazardous Air Pollutants
Notice of Intent
Oxides of nitrogen
New Source Performance Standard
New Source Review
Particulate matter less than l0 microns in size
Particulate matter less than 2.5 microns in size
Prevention of Significant Deterioration
Potential to Emit
Rules Series 307
Rules Series 307 - Section 401
Sulfur dioxide
Title IV of the Clean Air Act
Title V of the Clean Air Act
Tons per year
Utah Artministrative Code
Volatile organic compounds
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40 CFR
AO
BACT
CAA
CA.lq.A
CDS
CEM
CEMS
CFR
CMS
CO
COz
COze
COM
DAQruDAQ
DAQE
EPA
FDCP
GHG
GWP
IIAP or HAPs
ITA
LB/YR
MACT
MMBTU
NAA
NAAQS
NESHAP
NOI
NO*
NSPS
NSR
PMro
PMz.s
PSD
PTE
R307
R307401
SOz
Title IV
Title V
TPY
UAC
VOC
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I62 of 81 GP081AS-04780 1-PP-932
Appendix A.2
Accred itation Information
GP08 1AS-047801-PP-932
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Appendix *S"
Field Work Safety Plan
GP081AS-047801-PP-932
SITE SAFETY PLAN BOOKLET
Project: PRoJ-047801
Gustomer: EDL Enerqvffrans-Jordan
Location: South Jordan, Utah
Units: Landfill Gas Enoines #1. #2. #3
Client Project Manager: Chevnev Guvmon
Revision Date: June 29th,2023
68 of 81 GP08 1AS-04780 1-PP-932
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Page 1 of 2
Site Safety Plan and JHA Purpose and lnstructions
Purpose
Employee safety is the top priority of Montrose Environmental Group. All employees must be
trained to assess and mitigate hazards. The District Manager and Project Manager are
responsible to ensure all hazards have been properly identified and managed. Allemployees
have Stop Work Authority in all situations where an employee feels they or their co-worker
cannot perform a job safely or if there is a task for which they have not been adequately trained.
The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with
identifying physical and health hazards and determining how the hazards will be managed.
Additionally, the SSP will help each crew manage the safety of the employees by providing
emergency procedures and information. The booklet contains a several safety forms that may
be required in the field.
lnstructions
The SSP consists of the following:
1. A Pre-Mobilization Test Plan - To be completed in it's entirety by the client project Manager
prior to the test.
2. A Job Hazard Analysis is a standardized, two-page, flllable form that is used to evaluated the
task/site's particular hazards and controls. The form also includes a daily toolbox topic and
daily hazard review with sign off by the team. The client Project Manager is responsible to
complete the JHA form through section 8. Upon arrival at the test site, the team will review the
form for accuracy, making any corrections required and complete the remainder of the JHA.
Section 9 will require at least three tasks, hazards and controls be identified for the project.
Each team member has the option to discuss making changes or adding to the JHA and must
sign on the Job HazardAnalysis form in agreement and sign in Section 10. The JHA is to be
modified when conditions change. A toolbox meeting with a daily topic in addition to a review of
the hazard analysis is required daily for the duration of the test. An additional sheet of paper
with the toolbox topic and signatures can be added to the SSP packet.
3. Hazard Control Matrix - contains useful information on both engineering and
administrative controls that a crew can use to reduce or eliminate the hazards they have
observed plus applicable PPE that may be required.
4. Emergency Action Plan - The Job Supervisor/ Client Project Manager (CPM) will complete
the Emergency Action Plan form and ensure that all employees are familiar with the facility
emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior
to work commencing. ln the event of an emergency situation/ evacuation, the Job Supervisor/
CPM will maintain a roster and be responsible for accounting for all employees. The Job
Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed,
communicated to all employees, signed, and posted.
5. Additional Forms, as applicable
a. MEWP Lift lnspection Form
b. Heat Stress Prevention Form Based on Heat lndex
c. Extended Hours Form
AQS-FRM-1.13R1
GP08 1AS-047801-PP-93259 of 81
A\ Mt.)N lltL)\t
Page2 of 2
Site Safety Plan and JHA Purpose and lnstructions
The SSP is a living document. The Project Manager should continually update their SSPs as
new information and conditions change or if new hazards are presented.
Each completed SSP should be maintained with the Test Plan in the office for a period of 3
years. There will be an audit process developed for the Site Safety Plans.
AQS-FRM-1.13R1
GP08 1AS-047 80t-PP -93270 of 81
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Page 1 of2
PRE.MOBILIZATION TEST I N FORMATION
pROJECT NAME/LOCATION: EDL Enersyffrans-Jordan Landfitl PROJECT #. PROJ-047801
TEST DATE. January 14th and 15th, 202s PROJECT MANAGER: Cheyney Guymon
TEST SCOpE. NOx. CO, VOC T$ting on Three (3) CAT 3520C Engines (Permit lD'd as Landfill Gas Engines #1, #2, &#)
SITE CONTACT: Name: Summer Hitchens Contact Phone: (801) s69-8994
zatr
CO NOx SOz
0-1,000 ppm CO; 0-100 ppm NOx, 0-100 ppm VOC
tr
other
lf other, explain:
Toxic:
Engineering Controls to be lmplemented:
Corrosive:Dust:
Source Tvpe: New Source:
-
Revisit: X
Coal Fired Electric Utility: _ Ethanol Plant:
-CemenULime Kiln Plant: _ Specialty Mfg. of:Other: Municipal Landfill
Antlclpated Effluent Composltlon - check all that apply and fill in expected concentration in ppm/%
Prj#/Date/Tech:PROJ428605/Jan. 1 &1 8, 2O24lC. Guymon
ChemicalMfg. of
z
voc
Addltlonal Safety Equlpment Requlred:
Personal gas monitors: _
Respiratory Protection:
Half Face_ Full Face_ HEPA Filters- Supplied Air:
-
(Safety Dept. Approval)
Approxlmate Flue Gas Temperatures, (F)
above 950
tr
above
below 210
Approxlmate Duct Pressure, (lwg):
tr
below
lf other, explain:
210 to 450 450 to 950
tr
other
tr
other
a
-3 to +3
tr
+3 to +7
AQS-FRM.1.17
cP08 1AS-047 80t-PP -932
lf other, explain:
7t of 8t
+7
r1V"\ /vl()N Ilr\I\l
PRE.MOBILIZATION TEST IN FORMATION
Sampllng Locatlon: Stack Port _ Duct Port _
Approxlmate Sampllng Platform Helght, (ft)
Page 2 of 2
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below 6
lf other, explain:
a
50 to 100
tr
above 100
u
6to50
tr
other
Access and Protection:
Elevators: _ Ladders: _ MEWP Lift: _ Scaffold: _ Equipment Hoist: _
Guardrails: X Toe plate: _ Engineered Tie Off Points: _ Heat Shield: _
Other:
Describe how equipment wlll be mobilized to the sampling location:
Hoisted or hand canied
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Additional lnformation :
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Effluent Chemical Requlatory Limits
Gas Name Chemlcal
Formula
Cal OSHA PELI
(ppm)
Cal OSHA
STEL2
lonml
NIOSH REL
TWA3 (ppm)
Cal OSHA
Celllng(ooml
IDLHl
(ppm)
Oarbon Monoxide co 25 200 35 200 1,200
Nitric Oxide NO,25 ND5 25 ND 100
Sulfur Dioxide SOz 2 5 2 ND 100
Hvdrooen Chloride HCt 0.3 2 ND 2 50
Hydrogen Sulfide HzS '10 15 10 (10 min.)c 50 100
)alifomia Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) based on an 8-hour shift;
2: Cal OSHA ShorT-lerm Exposure Umit (STEL) based on a l5+ninute peiod;
3: National lnstitute tor Occupational Safety and Haalth (NIOSH) Recommended Exposure Linit (REL) Time-weighted Average (TWA) based
on an 8-hour shifr;
4: lmmediately Dangerous to lt1e or Heafth (IDLH);
5: Not Detined (ND);
C: Ceiling Limit - Maximum allowable human exposurc limit for an airbome or gasoous subsrance, whlch is not to be exceeded, even
momentaily.
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ps[s; November12,2024
AQS.FRM-1.17
GP08 1AS-04780 1-PP-932
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Joby Dunmire
72 of 8L
Date:
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-\ M( tN I ltl lri Job Hazard Analysis 1of3
Error Rlsk
f] time Pressure E Remote Work Location E > 12 hr shift E wo*ing > 8 consecutive dala
E Lack of procedures El Extreme temps, wind >30mph E Personal lllnesslfatigue E Vague work guidance
E Monotonous Activity E First day back after time off E Muttipte 1ob locations E Ottrer:
PPE E Hard Hats I Safety Glasses lsafety Toe Shoe/Boot ! Hearing Protection lsafety Spotter
E Hi-Vis Vests f1 Hamess/Lanyard" EI Goggles E Personal Monitor Type:
E Metatarsal Guards E Hot Gloves E Face Shield El Respirator Type:
ENomerdFRC E Other PPE:
AQS-FRM-1.18
73 of 8t GP081AS-047801-PP-932
Client EDL Eneroy/TEneJoKlsn Landfl I Sontact Name Sumffi Hhchms Date Jmuary 14 and 15,2025
Facilitv TEns.Jordan lrrdflll, South Jordil, UT SSP Writer PM
Client Rep
plete
out the Heat Stress Preventlon Form.
Job Prepara
[ .tou sitr
I satew
tlon
r Walk Through Completed I Site Specific Training Com
ork Permit Received from Client
lf the heat lndex ls expected to be above 91', fll
Faclllty lnformatlon/Emergency Preparedness
lf non+mergency medical attention is needed, call: AXIOM #: 877-502-9466.
Plant Emergency #
EMS Location
Certified First Aid Person:
Evacuation Routes Rally Point
Severe Weather Shelter Location Eye Wash & Safety Shower Location
EYes ENo
Source lnformatlon: (llst type):
Stack Gas Temp. fF) Stack Gas Press. ("H2O) Stack Gas Components:
Stack Gas lnhalation Potential? f]Y"" E Uo lf ves. see List of Hazard Chemicals.
Dust Hazards
Thermal Bum
Electrical Hazards
lnadequate Lighting
Slip and Trip
Hand Protection
Secondary Permits
Working from Heights
See alro Sect. 7
Electrical
Lifting
Respiratory
See also Sect, 8
Hazards Hazard Controls
E Dust Mask ! Goggles El Other:
EI Hot cloves E Heat Shields E Other Protective Clothing:
E Connections Protected from Elements fl Extemal GFCI El Other:
E Xp Rating Requirement I lntrinsically Safe Requirement
E lnstall Temporary Lighting E Headlamps
! Housekeeping E Banicade Area El Otner:
E Cut Resistant Gloves E Pinch Pts. E General E gteancat ! lmpact Resistianl
E othe.
Hazards for Conslderation
E Hot Work E Conlined Space f] Excavation
E r"tling objects E Fall protection E3 orop zone protectlon E plattorm load ratings
E Scaffota inspeclion E Ladder inspection f] Banicades for equipment
f] Exposed wire/connector ! Verifo equlpment groundinS E Arc Flash
E Crane lift plan E Rigging inspection E fag lines used E Holsts in place
El Unexpected exposure E Chemical fl Dust (combustible) E PEL provided
E Cartridoes or suoolied air available E Gas detection
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Additional Work Place Hazards
Job Hazard Analysis 2of3 I
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rltlcal Procedures - check all that apply - 'indicates additional form must be completed or collected from client
E Heat Sbess Prevention' E Confined Space* EI MEWP- E Roof Work E Scaffotd
ECota WeatherWork ! Hazardous Energy Control* E Exposure Monitoring E Other:
From Helghts
Fall Protection
Falling Objects Protection
Fall Hazard Communication
!E fixea Guardrails/Toe boards E fatt Prevention PPE Waming Line Sptem
! E Banicaoing tr Netting fl House Keeping fl Tethered Tools E catcn Blanket or Tarp
! E Adjacenyoverhead Workers ! Contractor Contact E Client Contact
]ther Gonslderations
Environmental Hazards - Weather Forecast
E Heaucold Etightning E Rain I snow f] lce E Tomado El wind Speed
Steps for Mitigation:
rctrical Safety Plannlng
Plant Hook up: E ttOV E 22OI24OV E egOV E Generator E Hard wired into panel
Electrical Classified Area: EYes ! No Trailer Grounded: EYes E ruo Plug Type
Electrical Hook Up Responsibility:
ist of Hazardous Ghemlcals
E Acetone E ttltric ecto
utner unemlGals:
E Hydrogen Peroide I Compressed Gases
E Hexane Esutfurlc Acid trl lsopropyl Alcohol I Flammable Gas
E Toluene E Hydrochloric Acid E LiquiO Nitrogen I Non-Flammable Gas
E Hzs El carbon Monoide
Steps for Mitigation:
lildlife/Fauna In Area
ElPoison ky flPoison oak Ilnsects:IWildlife:
Personnel w/ known allergies to bees stings or other allergens? EYes Euo
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AQS-FRM-1.18
GP08 1AS-047 80L-PP -932
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Hazards and Mitigatlon Steps
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rfp'r Mt )N I I{( )\t Job Hazard Analysis 3 of 3
11
IHA REVIEW: Crew Names & Slgnatures
Prlnted Name Slonature Date Prlnted Name Slgnature Date
JHA Meetinq & Review
to rsvlew:
r Change in conditions o Extended work hours o Daily Safety Topic
o Newworkers or conhactors r Occunence of near misses or injuries
domonstrates that slte condltlons and hazards havs not changed from the orlglna! SSP. lf changes dld occur, make the
updates to thls JHA and add notes as appllcable ln Sectlon 9.
Day Dlscusslon Toplc lnltlals
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Poge 1 of 2
EMERGENCY ACTION PLAN FORM
The Job Supewlsor/ Cllent ProJect Manager (CPM) wlll enoure that al! employees are famlllar wlth the faclllty emergency and evacuatlon
procedures, assembly/ rally points, alort strtsms, and signals prior to work commencing, ln the event of an emergency situation/
evacuatlon, the Job Supervlsor/ CPM wlt! maintatn a roster and be responslble for accountlng for all emploloes. The Job Supervlsor/
CPM will ensure that thls EmorgoncyAction Plan Form ls completed, communicated to all employees, and posted.
.Mou must follow the client's emergency actlon plan ffrst, and notlfy your Supervleor lmmedlately.
.lf incident Is llfe threatening, GALL 911 IMMEDIATELLY.[ non-emergency medlcal attentlon ls needed, call A)(OM Medlcal number: 877-502-9466.
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1 MEG Job Supervisor/ CPM's Name:
2 MEG Job Superuisor/ CPM's Telephone Number:
3 MEG Job Safety Supervisor (if applicable):
4 MEG Job Safety Supervisot's Telephone Number:
5 Plant's Emergency Telephone Number:
6 Local Hospltal/ GIinic Telephone Number:
7 Emergency Ops Radio Channel:
8 Plant's #1 Gontact Person's Name:
9 Plant's #1 Gontact Person's Telephone Number:
{0 Plant's #2 Contact Person's Name:
11 Plant's #2 Gontact Person's Telephone Number:
12 Designated Assembly Point Location:
13 Evacuation Routes:
14 Severe Weather Shelter Location:
15 Eye Wash and Safety Shower Location:
16 The First Ald Kit is Located:
17 The Fire Extinguisher is Located:
AQS-FRM-1.11
75 of 81 GP08 1AS-04780 1-PP-932
Poge 2 ol 2&\ M()N llt(,\t
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EMERGENCY EVACUATION AND ASSEMBLY MAP
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1 Facility Name:
2 Facility Alarm (Circle):YES or NO
3
Alarm Tones:
TIKE:
CHEMICAU
SHELTER.IN-PUCE: :
4 Designated Shelter(s) Descri ption :
5 Designated Assembly Point(s) Descriptlon:
N*+'
S
EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBTY MAP REVIEW: Crew Names and Signatures
Prlnted Name:Sionoture: Ddte: Printed Nome:Slgnature: Dote:
AQS-FRM-1.11
77 of 8l G P08 1AS- 047 80 L -PP -932
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Page 1 of 1
Daily MEWP Lift lnspection Form
All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used
atthe beginning of each shift or following 6 to 8 hours of use.
MEWP Lift Model #:Serial Number:
Make:Rented or Owned:
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Yes No N/A
nD!
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. Check Yes" if an item is adequate, operational, and safe.o Check "No" to indicate that a repair or other conective action is required prior to use.. Check "N/A" to indicate 'Not Applicable.'
Items to be lnspected
1. All MEWP lift components are in working condition (i.e. no loose or missing parts, tom or
loose hoses, etc.) - if something can be easily loosened by hand then it is not sufficient.
2. Hydraulic fluid level is sufficient, with the platform fully lowered
3. Hydraulic system pressure (see manufacturer specs) is acceptable.
lf the pressure is low, determine cause and repair in accordance with accepted prccedures
as outlined in service manual.
4. Tires and wheel lug nuts (for tightness)
5. Hoses and cables (i.e. worn areas or chafing)
6. Platform rails and safety gate (no damage present)
7. Pivot pins secure
8. Welds are not cracked and structural members are not bent or broken
9. Warning and instructional labels are legible and secure, and load capacity is clearly marked.
10. Manufacture/s lnstruction Manual is present inside the bucket
11. Base controls (switches and push buttons) can be properly operaled
12. Platform conditions are safe (i.e. not slippery)
13. Fire extinguisher is present, mounted and fully charged, located inside the bucket
14. Headlights, safety strobe light and back-up alarm are functional
15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds,
etc.) 'Do not operate If winds are 20 mph, unless otherwlee epeclfled by manufacturer
recommendatlons.
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Operator Name & Signature Location Date
tGround Control Name & Signature Location Date
Hamess lnspectlons:I
Printed Name Signature Date t
Printed Name Signature Date
IPrinted Name
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Signature Date
AOS-FRM-1.16
GP08 1AS-047801-PP-932 I
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A/i\ MofirRosE Page 1 of 1
Extended Hours Safety Audit
Project Number:Date:Time:
When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate
the condition of the crew, and the safety of the work environment.
Permission to proceed into extended work hours must come from a District Manager (DM) or RegionalVice
President (RVP). Technical RVPs can authorize moving fonryard, if they are in the field or if they are
managing the project.
1. Hold test crew meetins Test crew initials:
a
a
a
a
a
a
Temperature and weather
Lighting
Working from Heights
Hoisting
PPE (i.e. respirators, etc.)
Pollutant concentration in ambient air (SOz,
HzS, ect.)
Notifv DM or RVP
The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the
extended work period. lf the DM is the acting PM on the job site, they must contact the RVP.
During this time, they can come to an agreement on how to proceed. ltemsto discuss include:
a
a
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Reason for extended hours
Reason for delay
Production I im itations
lmpending Weather
Contac-t the client
The PM, DM or RVP must discuss with client any identified safety concems, the client's needs and
mutually agree on how to proceed. Discussion should also include the appropriate rest period
needed before the next day's work shift can begin. The DM and/or a RVP must be informed on the
finaldecision.
Flnal Outcome:
Approver:
OOlAS-SAFETY-FM-3
GP08 1AS-047 80L-PP -932
The test leader should look for signs of the following in their crews:
o lnitabilityr Lack of motivation. Headaches. Giddiness
o Fatigue. Depression. Reduced alertness, lack of concentration and
memory
The test leader should assess the environmental and hazardous concems:
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.^-:-.-"",,; :-- .1 J ---']"1:.,;
^::,,"'',*:,]dl
Nausea or vomifinS
-- Rapid, strong pulse
Cool, pale,
clammy 3klo
NaoscJ or vomrnnS
Rapicl, weak pulse @
Muscle cramps
1.
2.
Page 1 of 1
Heat Stress Prevention Form
This form is to be used when the Expected Heat lndex is above 91' F, and is to be kept with project
documentation.
Proiect Manaqer (PM):Exoected Hioh Temo:
Date(s):Exoected Heat lndex:
Review the signs of Heat Exhaustion and Heat Stroke
lf Heat lndex is above 91' F:o Provide cold water and/or sports drinks to all field staff (avoid caffeinated drinks and energy
drinks which can increase core temperature).
o Bring no less than one gallon of water per employee. lf employee(s) are dehydrated, on blood pressure medication or not acclimated to heat,
ensure they are aware of the heightened risk for heat illness. Provide cool head bands/vests/etc.. Have ice available to employees. lmplement work shift rotations and breaks, particularly for employees working in direct
sunlight.. Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable
temporary structures.. PM should interview each field staff periodically to evaluate for signs of heat illness
lf Heat lndex is above 103" F:. Employees must stop for drinks and breaks every hour (about 4 cups/hour). Employees are not permitted to work alone for more than one hour at a time without a
break offering shade and drinks. Employees should wear cool bands and vests if working outside more than one hour at a
time. PM should interview each field staff every 2 hours to evaluate for signs of heat illness
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OOlAS-SAFETY-FM-5
G P0B 1AS-047 80L-PP -93280 of 81
This is the Last Page of This Document
If you have any questions, please contact one of the following
individuals by email or phone.
Name: Beckie Hawkins
Title: District Manager
Region: Great Plains Region, Utah Office
Email: [e-mail]
Phone: 80 L-794-2950
UITNU I.\EPARIMFNT OF
ENVrRoNMENTAL !u^LlIY
Name:
Title:
Region:
Email:
Phone:
Cheyney Guymon
Client Project Manager
Great Plains Region, Utah Office
chg uymon @ montrose-env. com
801-362 -4978
t---I n,n', 2 ) ?r?i it'lr
OIVISION OF AIR OUALITY
81 of 81 GP08 1AS-047801-PP-932