DAQ-2025-001447

DAQE-AN157920002-25

{{$d1 }}

Rob Richards
ROC Fund Landfill Holdings, LLC
PO Box 1889
Salt Lake City, UT 84110
[e-mail]

Dear Mr. Richards:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN157920001-22 to
Replace Equipment
Project Number: N157920002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on January
23, 2025. ROC Fund Landfill Holdings, LLC must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Stockton Antczak, 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 right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:SA:jg

cc: Utah County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

March 6, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN157920002-25
Administrative Amendment to Approval Order
DAQE-AN157920001-22 to Replace Equipment

Prepared By
Stockton Antczak, Engineer
[phone]
[e-mail]

Issued to
ROC Fund Landfill Holdings, LLC - Intermountain Regional MSW Landfill

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

March 6, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 6
ACRONYMS ................................................................................................................................. 7

DAQE-AN157920002-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
ROC Fund Landfill Holdings, LLC ROC Fund Landfill Holdings, LLC - Intermountain Regional MSW Landfill

Mailing Address Physical Address
PO Box 1889 800 South Allen Ranch Road
Salt Lake City, UT 84110 Fairfield, UT 84013

Source Contact UTM Coordinates
Name: Rob Richards 409098 m Easting
Phone: [phone] 4452389 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 4953 (Refuse Systems)

SOURCE INFORMATION
General Description
ROC Fund Landfill Holdings, LLC (ROC) owns and operates the Intermountain Regional MSW Landfill
in Fairfield. The facility accepts municipal and commercial waste.

NSR Classification
Administrative Amendment

Source Classification
Located in Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA
Utah County
Airs Source Size: B

Applicable Federal Standards
State Plans (Part 62), OOO - Federal Plan Requirements for Municipal Solid Waste Landfills
That Commenced Construction On or Before July 17, 2014, and Have Not Been Modified or
Reconstructed Since July 17, 2014
MACT (Part 63), A: General Provisions
MACT (Part 63), AAAA: National Emission Standards for Hazardous Air Pollutants:
Municipal Solid Waste Landfills
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source
DAQE-AN157920002-25
Page 4

Project Description
ROC currently powers the landfill gas collection system (LGCS) using two Cummins diesel engines rated
at 70 kW. These engines require a larger workload than the LGCS flare and blowers need in order to run
efficiently and effectively. This lack of load on the Cummins engines has led to several issues and
shutdowns. ROC is proposing to replace these existing engines with two new CAT diesel generators rated
at 30 kW. The new generators are smaller and better suited to the workload capacity of the LGCS. The
new generators will operate under the same requirements as the previous engines and will result in a
decrease in emissions.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 34081.00
Carbon Monoxide -0.45 93.51
Nitrogen Oxides -2.07 17.94
Particulate Matter - PM10 -0.15 3.81
Particulate Matter - PM2.5 -0.15 3.81
Sulfur Dioxide -0.14 8.96
Volatile Organic Compounds -0.17 8.93

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 1640
Change (TPY) Total (TPY)
Total HAPs 0 0.82

SECTION I: GENERAL PROVISIONS

I.1 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]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
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 representative upon
request, and the records shall include the five-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 five years. [R307-401-8]

DAQE-AN157920002-25
Page 5

I.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 control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the 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. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
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 18 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Intermountain Regional MSW Landfill II.A.2 Two Flare Station Generator Engines Rating: 30 kW each (40.2 hp each) Fuel: Ultra-low Sulfur Diesel (ULSD) Federal Applicability: NSPS Subpart IIII and MACT Subpart ZZZZ
II.A.3 Scale House Generator Engine Rating: 20 kW (27 hp) Fuel: ULSD Federal Applicability: NSPS Subpart IIII and MACT Subpart ZZZZ II.A.4 Candlestick Flare Capacity: 2,000 scfm
II.A.5 Intermountain Regional MSW Landfill Class V Municipal Solid Waste Landfill with a 27 million cubic feet capacity. 40 CFR 62 Subpart OOO, and NESHAP AAAA apply to this unit.

DAQE-AN157920002-25
Page 6

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission units to exceed
the following values:

A. Candlestick Flare - 20% opacity

B. 20% diesel-fired generator engines and all other sources.

[R307-401-8]

II.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. [R307-401-8]
II.B.1.b The owner/operator shall meet all applicable requirements of 40 CFR 62 Subpart OOO - Federal
Plan Requirements for Municipal Solid Waste Landfills That Commenced Construction On or
Before July 17, 2014, and Have Not Been Modified or Reconstructed Since July 17, 2014, and
40 CFR 63 Subpart AAAA National Emission Standards for Hazardous Air Pollutants:
Municipal Solid Waste Landfills. [40 CFR 62 Subpart OOO, 40 CFR 63 Subpart AAAA]

II.B.2 Engine Requirements
II.B.2.a The owner/operator shall not operate more than one 30 kW engine at one time. [R307-401-8]

II.B.2.a.1 The owner/operator shall: A. Record the date and time that each 30 kW engine operated B Maintain records of maintenance and testing on a daily basis. [R307-401-8]
II.B.2.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the engines. [R307-401-8]

II.B.2.c The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.c.1 To demonstrate compliance with the fuel sulfur 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 fuel
sulfur requirement. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN157920001-22 dated December 15, 2022 Is Derived From NOI dated January 23, 2025

DAQE-AN157920002-25
Page 7

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN157920002
February 5, 2025

Rob Richards
ROC Fund Landfill Holdings, LLC
PO Box 1889
Salt Lake City, UT 84110
[e-mail]

Dear Rob Richards,

Re: Engineer Review - Administrative Amendment:
Administrative Amendment to Approval Order DAQE-AN157920001-22 to Replace Equipment
Project Number: N157920002

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review (NSR) permitting program. ROC Fund
Landfill Holdings, LLC should complete this review within 10 business days of receipt.

ROC Fund Landfill Holdings, LLC should contact Stockton Antczak at [phone] if there are
questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Stockton Antczak at [e-mail] the signed cover letter. Upon receipt of the
signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.

If ROC Fund Landfill Holdings, LLC does not respond to this letter within 10 business days, the project
will move forward without source concurrence. If ROC Fund Landfill Holdings, LLC has concerns that
cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.

Approval Signature _____________________________________________________________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

02/28/2025

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N157920002
Owner Name ROC Fund Landfill Holdings, LLC
Mailing Address PO Box 1889
Salt Lake City, UT, 84110

Source Name ROC Fund Landfill Holdings, LLC- Intermountain Regional
MSW Landfill
Source Location 800 South Allen Ranch Road
Fairfield, UT 84013

UTM Projection 409098 m Easting, 4452389 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 4953 (Refuse Systems)

Source Contact Rob Richards
Phone Number [phone]
Email [e-mail]

Billing Contact
Phone Number
Email

Project Engineer Stockton Antczak, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted January 23, 2025
Date of Accepted Application January 30, 2025

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 2
SOURCE DESCRIPTION

General Description
ROC Fund Landfill Holdings, LLC (ROC) owns and operates the Intermountain Regional MSW
Landfill in Fairfield. The facility accepts municipal and commercial waste.

NSR Classification:
Administrative Amendment

Source Classification
Located in , Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA,
Utah County
Airs Source Size: (No size assigned)

Applicable Federal Standards
State Plans (Part 62), A: General Provisions
State Plans (Part 62), OOO - Federal Plan Requirements for Municipal Solid Waste Landfills
That Commenced Construction On or Before July 17, 2014 and Have Not Been Modified or
Reconstructed Since July 17, 2014
MACT (Part 63), A: General Provisions
MACT (Part 63), AAAA: National Emission Standards for Hazardous Air Pollutants:
Municipal Solid Waste Landfills
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Proposal
Administrative Amendment to Approval Order DAQE-AN157920001-22 to Replace Equipment

Project Description
ROC currently powers the landfill gas collection system (LCGS) using two Cummins Diesel
engines rated at 70 kW. These engines require a larger workload than the LCGS flare and blowers
need in order to run efficiently and effectively. This lack of load on the Cummins engines has led
to several issues and shutdowns. ROC is proposing to replace these existing engines with two
new CAT Diesel generators rated at 30 kW. The new generators are smaller and better suited to
the workload capacity of the LCGS. The new generators will operate under the same
requirements as the previous engines, and will result in a decrease in emissions.

EMISSION IMPACT ANALYSIS
Emissions from the change in equipment will decrease the PTEs of the site. No modeling thresholds have been
met so no modeling analysis is required at this time. [Last updated January 24, 2025]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 3
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 34081.00
Carbon Monoxide -0.45 93.51
Nitrogen Oxides -2.07 17.94
Particulate Matter - PM10 -0.15 3.81
Particulate Matter - PM2.5 -0.15 3.81
Sulfur Dioxide -0.14 8.96
Volatile Organic Compounds -0.17 8.93

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 1640
Change (TPY) Total (TPY)
Total HAPs 0 0.82

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 4
Review of BACT for New/Modified Emission Units

2. BACT review regarding Change in Equipment
The source has requested to replace their current 70 kW generators with two smaller generators
both rated at 30 kW. These two new generators are Tier IV and will be under the same BACT
requirements as the previous generators. No BACT analysis is required at this time. [Last updated
January 24, 2025]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 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]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

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 representative upon
request, and the records shall include the five-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 five (5) years. [R307-401-8]

I.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 control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the 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. [R307-
401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 5
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 18 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Intermountain Regional MSW Landfill

II.A.2 Two (2) Flare Station Generator Engines
Rating: 30 kW each ( 40.2 hp each)
Fuel: Ultra-low Sulfur Diesel (ULSD)
Federal Applicability: NSPS Subpart IIII and MACT Subpart ZZZZ
II.A.3 Scale House Generator Engine
Rating: 20 kW (27 hp)
Fuel: ULSD
Federal Applicability: NSPS Subpart IIII and MACT Subpart ZZZZ
II.A.4 Candlestick Flare
Capacity: 2,000 scfm
II.A.5 Intermountain Regional MSW Landfill
Class V Municipal Solid Waste Landfill with a 27 million cubic feet capacity. 40 CFR 62
Subpart OOO, and NESHAP AAAA applies to this unit.

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission units to
exceed the following values:

A. Candlestick Flare - 20% opacity

B. 20% diesel-fired generator engines and all other sources. [R307-401-8]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 6
II.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. [R307-401-8]

II.B.1.b
NEW
The owner/operator shall meet all applicable requirements of 40 CFR 62 Subpart OOO -
Federal Plan Requirements for Municipal Solid Waste Landfills That Commenced
Construction On or Before July 17, 2014 and Have Not Been Modified or Reconstructed
Since July 17, 2014, and 40 CFR 63 Subpart AAAA National Emission Standards for
Hazardous Air Pollutants: Municipal Solid Waste Landfills. [40 CFR 62 Subpart OOO, 40
CFR 63 Subpart AAAA]

II.B.2 Engine Requirements
II.B.2.a
NEW
The owner/operator shall not operate more than one 30 kW engine at one time. [R307-401-8]

II.B.2.a.1
NEW
The owner/operator shall:

A. Record the date and time that each 30 kW engine operated

B Maintain records of maintenance and testing on a daily basis. [R307-401-8]

II.B.2.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in the engines. [R307-401-8]

II.B.2.c The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.2.c.1
NEW
To demonstrate compliance with the fuel sulfur 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 fuel sulfur requirement. [R307-401-8]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 7
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN157920001-22 dated December 15, 2022
Is Derived From NOI dated January 23, 2025

REVIEWER COMMENTS

1. Comment regarding Summary of Changes:
The two generators powering the LGCS were downsized from 70 kW to 30 kW. Condition II.A.2 of
the equipment list was updated to reflect the rating of the new generators. Conditions II.B.2.a and
II.B.2.a.1 were also updated to include the new generator power rating. [Last updated January 24,
2025]

2. Comment regarding Emissions Calculations:
The old and new generators were assumed to fall into the same generator category in the State and
local Emissions Inventory System (SLEIS) and so the same emission factors were applied as in the
original emission calculations. Using fuel consumption data collected in 2023, the source predicted
the future fuel consumption of the new generators based on the difference in the power ratings of the
generators. This lower fuel consumption and the emission factors for the generators were then used
to calculate the reduction in emissions. [Last updated January 24, 2025]

3. Comment regarding NSPS and MACT Applicability:
40 CFR 60 Subpart IIII applies to owners and operators of stationary CI ICE that commence
construction after July 11, 2005, where the stationary CI ICE are manufactured after April 1, 2006.
Subpart IIII applies to the diesel-fired engines. The source must comply with the emission limits
contained in the AO or the emission limits contained in NSPS Subpart IIII, whichever is more
stringent. In addition, Subpart IIII contains other monitoring, recordkeeping, and reporting
requirements.

40 CFR 60 Subpart XXX applies to municipal solid waste landfills that commenced construction,
reconstruction, or modification after July 17, 2014. The proposed construction at this site are solely
to comply with Subpart WWW; therefore, Subpart XXX does not apply to this source.

40 CFR 62 Subpart OOO applies to municipal solid waste landfills that commenced construction on
or before July 17, 2014. Subpart OOO is applicable to the source. As the landfill has a NMOC
emission rate greater than 34 megagrams per year, the source is subject to the requirements listed in
Subpart OOO.

40 CFR 63 Subpart AAAA applies to municipal solid waste landfills with a design capacity equal to
or greater than 2.5 million megagrams (Mg) and 2.5 million m3 and has estimated uncontrolled
emissions equal to or greater than 50 megagrams per year NMOC. Subpart AAAA applies to this
source.

40 CFR 63 Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area
source of HAP emissions. Subpart ZZZZ applies to the three diesel-fired engines on site.
Compliance with MACT Subpart ZZZZ is meeting the requirements of NSPS Subpart IIII.

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 8
[Last updated February 5, 2025]

4. Comment regarding Title V Applicability:
Landfills are area sources subject to a federal plan (40 CFR 62 Subpart OOO). Therefore this source
is a Title V source. This facility has operated under a Title V permit since the landfill opened in
2012. [Last updated February 5, 2025]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill
February 5, 2025
Page 9
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN157920002 February 5, 2025 Rob Richards
ROC Fund Landfill Holdings, LLC PO Box 1889 Salt Lake City, UT 84110
[e-mail] Dear Rob Richards,
Re: Engineer Review - Administrative Amendment: Administrative Amendment to Approval Order DAQE-AN157920001-22 to Replace Equipment Project Number: N157920002 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. ROC Fund Landfill Holdings, LLC should complete this review within 10 business days of receipt. ROC Fund Landfill Holdings, LLC should contact Stockton Antczak at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns,
please email Stockton Antczak at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If ROC Fund Landfill Holdings, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If ROC Fund Landfill Holdings, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction. Approval Signature _____________________________________________________________
(Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N157920002 Owner Name ROC Fund Landfill Holdings, LLC Mailing Address PO Box 1889
Salt Lake City, UT, 84110 Source Name ROC Fund Landfill Holdings, LLC- Intermountain Regional
MSW Landfill Source Location 800 South Allen Ranch Road Fairfield, UT 84013
UTM Projection 409098 m Easting, 4452389 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4953 (Refuse Systems) Source Contact Rob Richards Phone Number [phone] Email [e-mail] Billing Contact
Phone Number Email
Project Engineer Stockton Antczak, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted January 23, 2025 Date of Accepted Application January 30, 2025

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 2
SOURCE DESCRIPTION General Description
ROC Fund Landfill Holdings, LLC (ROC) owns and operates the Intermountain Regional MSW Landfill in Fairfield. The facility accepts municipal and commercial waste.
NSR Classification: Administrative Amendment Source Classification Located in , Southern Wasatch Front O3 NAA, Provo UT PM2.5 NAA, Utah County Airs Source Size: (No size assigned) Applicable Federal Standards State Plans (Part 62), A: General Provisions State Plans (Part 62), OOO - Federal Plan Requirements for Municipal Solid Waste Landfills
That Commenced Construction On or Before July 17, 2014 and Have Not Been Modified or Reconstructed Since July 17, 2014 MACT (Part 63), A: General Provisions
MACT (Part 63), AAAA: National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source Project Proposal Administrative Amendment to Approval Order DAQE-AN157920001-22 to Replace Equipment
Project Description ROC currently powers the landfill gas collection system (LCGS) using two Cummins Diesel engines rated at 70 kW. These engines require a larger workload than the LCGS flare and blowers need in order to run efficiently and effectively. This lack of load on the Cummins engines has led to several issues and shutdowns. ROC is proposing to replace these existing engines with two new CAT Diesel generators rated at 30 kW. The new generators are smaller and better suited to the workload capacity of the LCGS. The new generators will operate under the same requirements as the previous engines, and will result in a decrease in emissions.
EMISSION IMPACT ANALYSIS Emissions from the change in equipment will decrease the PTEs of the site. No modeling thresholds have been met so no modeling analysis is required at this time. [Last updated January 24, 2025]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 34081.00 Carbon Monoxide -0.45 93.51
Nitrogen Oxides -2.07 17.94
Particulate Matter - PM10 -0.15 3.81
Particulate Matter - PM2.5 -0.15 3.81
Sulfur Dioxide -0.14 8.96
Volatile Organic Compounds -0.17 8.93 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 1640
Change (TPY) Total (TPY)
Total HAPs 0 0.82

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 4
Review of BACT for New/Modified Emission Units 2. BACT review regarding Change in Equipment
The source has requested to replace their current 70 kW generators with two smaller generators both rated at 30 kW. These two new generators are Tier IV and will be under the same BACT requirements as the previous generators. No BACT analysis is required at this time. [Last updated
January 24, 2025]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
I.1 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]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] 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 representative upon request, and the records shall include the five-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 five (5) years. [R307-401-8]

I.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 control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the 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. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 5
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 18 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Intermountain Regional MSW Landfill

II.A.2 Two (2) Flare Station Generator Engines Rating: 30 kW each ( 40.2 hp each) Fuel: Ultra-low Sulfur Diesel (ULSD)
Federal Applicability: NSPS Subpart IIII and MACT Subpart ZZZZ
II.A.3 Scale House Generator Engine Rating: 20 kW (27 hp) Fuel: ULSD Federal Applicability: NSPS Subpart IIII and MACT Subpart ZZZZ
II.A.4 Candlestick Flare Capacity: 2,000 scfm
II.A.5 Intermountain Regional MSW Landfill Class V Municipal Solid Waste Landfill with a 27 million cubic feet capacity. 40 CFR 62 Subpart OOO, and NESHAP AAAA applies to this unit.

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission units to
exceed the following values:
A. Candlestick Flare - 20% opacity
B. 20% diesel-fired generator engines and all other sources. [R307-401-8]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 6
II.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. [R307-401-8]
II.B.1.b NEW The owner/operator shall meet all applicable requirements of 40 CFR 62 Subpart OOO - Federal Plan Requirements for Municipal Solid Waste Landfills That Commenced Construction On or Before July 17, 2014 and Have Not Been Modified or Reconstructed Since July 17, 2014, and 40 CFR 63 Subpart AAAA National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills. [40 CFR 62 Subpart OOO, 40 CFR 63 Subpart AAAA] II.B.2 Engine Requirements II.B.2.a NEW The owner/operator shall not operate more than one 30 kW engine at one time. [R307-401-8] II.B.2.a.1 NEW The owner/operator shall: A. Record the date and time that each 30 kW engine operated B Maintain records of maintenance and testing on a daily basis. [R307-401-8] II.B.2.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the engines. [R307-401-8]
II.B.2.c The owner/operator shall only combust diesel fuel that meets a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.c.1 NEW To demonstrate compliance with the fuel sulfur 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 fuel sulfur requirement. [R307-401-8]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 7
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN157920001-22 dated December 15, 2022
Is Derived From NOI dated January 23, 2025
REVIEWER COMMENTS

1. Comment regarding Summary of Changes: The two generators powering the LGCS were downsized from 70 kW to 30 kW. Condition II.A.2 of the equipment list was updated to reflect the rating of the new generators. Conditions II.B.2.a and II.B.2.a.1 were also updated to include the new generator power rating. [Last updated January 24, 2025] 2. Comment regarding Emissions Calculations: The old and new generators were assumed to fall into the same generator category in the State and local Emissions Inventory System (SLEIS) and so the same emission factors were applied as in the original emission calculations. Using fuel consumption data collected in 2023, the source predicted the future fuel consumption of the new generators based on the difference in the power ratings of the
generators. This lower fuel consumption and the emission factors for the generators were then used to calculate the reduction in emissions. [Last updated January 24, 2025]
3. Comment regarding NSPS and MACT Applicability: 40 CFR 60 Subpart IIII applies to owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE are manufactured after April 1, 2006.
Subpart IIII applies to the diesel-fired engines. The source must comply with the emission limits contained in the AO or the emission limits contained in NSPS Subpart IIII, whichever is more stringent. In addition, Subpart IIII contains other monitoring, recordkeeping, and reporting requirements. 40 CFR 60 Subpart XXX applies to municipal solid waste landfills that commenced construction, reconstruction, or modification after July 17, 2014. The proposed construction at this site are solely to comply with Subpart WWW; therefore, Subpart XXX does not apply to this source.
40 CFR 62 Subpart OOO applies to municipal solid waste landfills that commenced construction on or before July 17, 2014. Subpart OOO is applicable to the source. As the landfill has a NMOC emission rate greater than 34 megagrams per year, the source is subject to the requirements listed in Subpart OOO.
40 CFR 63 Subpart AAAA applies to municipal solid waste landfills with a design capacity equal to or greater than 2.5 million megagrams (Mg) and 2.5 million m3 and has estimated uncontrolled emissions equal to or greater than 50 megagrams per year NMOC. Subpart AAAA applies to this source. 40 CFR 63 Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area source of HAP emissions. Subpart ZZZZ applies to the three diesel-fired engines on site.
Compliance with MACT Subpart ZZZZ is meeting the requirements of NSPS Subpart IIII.

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 8
[Last updated February 5, 2025]
4. Comment regarding Title V Applicability: Landfills are area sources subject to a federal plan (40 CFR 62 Subpart OOO). Therefore this source is a Title V source. This facility has operated under a Title V permit since the landfill opened in
2012. [Last updated February 5, 2025]

Engineer Review N157920002: ROC Fund Landfill Holdings, LLC- Intermountain Regional MSW Landfill February 5, 2025 Page 9
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
Stockton Antczak <[e-mail]>
Engineering Review for Intermountain Regional Landfill Permitting Project
2 messages
Stockton Antczak <[e-mail]>Wed, Feb 26, 2025 at 3:11 PM
To: "[e-mail]" <[e-mail]>, Joshua Hortin <[e-mail]>, Morgan Wilkins
<[e-mail]>
All,
Attached is my engineering review for the project at the Intermountain Regional Landfill. Sorry it took a little longer than
expected, it got a bit lost in the peer review process. But it is ready for your review now. If you could look it over and let
me know if you have any comments or questions I would appreciate it. It should be nearly identical to the current permit,
just with the generator information changed.
Thanks,
Stockton
--
Stockton J. Antczak | Permitting Engineer | Major New Source Review
385-306-6724 (cell)
195 North 1950 West, Salt Lake City, UT 84116
RN157920002.rtf
1481K
Morgan Wilkins <[e-mail]>Fri, Feb 28, 2025 at 8:09 AM
To: Stockton Antczak <[e-mail]>, "[e-mail]" <[e-mail]>, Joshua Hortin
<[e-mail]>
Good morning Stockton,

The Engineer Review you sent Wednesday, February 26th has been reviewed and I’ve attached the signed letter to this
email.
I’d also like to circle back to an email you sent on Wednesday, February 5th in reference to contact information- Rob
Richards is still the source contact.

Thank you,

Morgan Wilkins
Environmental Scientist
2/28/25, 1:50 PM State of Utah Mail - Engineering Review for Intermountain Regional Landfill Permitting Project
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-a:r-2750211212410516957&simpl=msg-a:r604921905220403…1/3
Caution: External
BS Geology

HANSEN, ALLEN & LUCE
859 W. South Jordan Pkwy. Ste. 200
South Jordan, UT 84095
O: 801.566.5599

Click below to learn about HAL’s legacy of serving your community for over 50 years!

From: Stockton Antczak <[e-mail]>
Sent: Wednesday, February 26, 2025 3:11 PM
To: [e-mail]; Joshua Horn <[e-mail]>; Morgan Wilkins
<[e-mail]>
Subject: Engineering Review for Intermountain Regional Landfill Perming Project

All,

Attached is my engineering review for the project at the Intermountain Regional Landfill. Sorry it took a little longer than
expected, it got a bit lost in the peer review process. But it is ready for your review now. If you could look it over and let
me know if you have any comments or questions I would appreciate it. It should be nearly identical to the current permit,
just with the generator information changed.

Thanks,
Stockton

--
Stockton J. Antczak | Permitting Engineer | Major New Source Review
385-306-6724 (cell)
2/28/25, 1:50 PM State of Utah Mail - Engineering Review for Intermountain Regional Landfill Permitting Project
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-a:r-2750211212410516957&simpl=msg-a:r604921905220403…2/3
[Quoted text hidden]
SIGNED RN157920002 PDF.pdf
576K
2/28/25, 1:50 PM State of Utah Mail - Engineering Review for Intermountain Regional Landfill Permitting Project
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-a:r-2750211212410516957&simpl=msg-a:r604921905220403…3/3
Stockton Antczak <[e-mail]>
Notice of Intent - Intermountain Regional Landfill Generator Replacement
8 messages
Joshua Hortin <[e-mail]>Thu, Jan 23, 2025 at 11:05 AM
To: "[e-mail]" <[e-mail]>
Cc: Andrew Alvaro <[e-mail]>, "[e-mail]" <[e-mail]>, "[e-mail]"
<[e-mail]>
Hello,
Aached is a leer noce of intent, submied on behalf of Intermountain Regional Landfill, to replace two generators
listed in their Title V permit with smaller generators. Aached to the leer is an emissions calculaon sheet for the
old and new generators. Please reach out to myself or Andrew Alvaro with any quesons or concerns. If you would
like a hard copy of these or any other documents, we can arrange to deliver those to your office. Thank you!
Joshua Hortin, PE
Civil and Environmental Engineer

HANSEN, ALLEN & LUCE
859 W. South Jordan Pkwy. Ste. 200
South Jordan, UT 84095
O: 801.566.5599 | C: 801.668.4265

Click below to learn about HAL’s legacy of serving your community for over 50 years!

NOI - Replacement Generators IRL.pdf
444K
Stockton Antczak <[e-mail]>Thu, Jan 23, 2025 at 11:09 AM
To: Jon Black <[e-mail]>
Jon,
Here is the NOI for the intermountain landfill project I had done the pre-NOI meeting for. I'll get the project created as an
admin project since the source is just downsizing two engines and the emissions are all decreasing. Besides you, Jeff
Robb, and Andrea Riddle, is there someone else I need to send the project ID to? I remember something being said
about a new employee in the training yesterday but I can't remember the name.
Thanks,
Stockton
[Quoted text hidden]
NOI - Replacement Generators IRL.pdf
444K
Stockton Antczak <[e-mail]>Thu, Jan 23, 2025 at 11:29 AM
To: Joshua Hortin <[e-mail]>
Joshua,
2/28/25, 1:50 PM State of Utah Mail - Notice of Intent - Intermountain Regional Landfill Generator Replacement
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1822063882924988561&simpl=msg-f:182206388292498856…1/4
This looks good so far. I'll look it over and get started on it. I'll let you know if there is any additional information that I
need.
Thanks,
Stockton
[Quoted text hidden]
Jon Black <[e-mail]>Thu, Jan 23, 2025 at 1:07 PM
To: Stockton Antczak <[e-mail]>
Thank you Stockton,
I have updated the WAL for you. Also, please email Christine Wilson who is the new DAQ employee who will enter these
ID numbers for us. She also shows up in the WAL now.
Also, when you are doing the engineering review could you update the AIRS Source Size to 'SM' instead of B. The 93
tons of CO falls above the SM80 level which requires Major Compliance Review instead of Minor Compliance Review.
Let me know if you have any questions.
thank you,
Jon
[Quoted text hidden]
--
Jon L. Black | Manager | Major New Source Review
801.536.4047 (office) | 801.536.4099 (fax) | 385.306.6511 (cell)
195 North 1950 West, Salt Lake City, UT 84116
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
Stockton Antczak <[e-mail]>Fri, Jan 24, 2025 at 3:34 PM
To: Jon Black <[e-mail]>
I've been looking into how to change the AIRS source size to SM but I haven't been able to figure out how to change it. Do
I do that in TEMPO? If so, where do I find that?
[Quoted text hidden]
Joshua Hortin <[e-mail]>Thu, Feb 6, 2025 at 10:28 AM
To: Stockton Antczak <[e-mail]>
Hi Stockton,
Thanks for working on this! I know mes can vary and it's probably early to be expecng anything, but do you have
any updates or esmates on this AO?
Thanks!
Joshua Hortin, PE
2/28/25, 1:50 PM State of Utah Mail - Notice of Intent - Intermountain Regional Landfill Generator Replacement
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1822063882924988561&simpl=msg-f:182206388292498856…2/4
Caution: External
Civil and Environmental Engineer

HANSEN, ALLEN & LUCE
859 W. South Jordan Pkwy. Ste. 200
South Jordan, UT 84095
O: 801.566.5599 | C: 801.668.4265

Click below to learn about HAL’s legacy of serving your community for over 50 years!

From: Stockton Antczak <[e-mail]>
Sent: Thursday, January 23, 2025 11:29 AM
To: Joshua Horn <[e-mail]>
Subject: Re: Noce of Intent - Intermountain Regional Landfill Generator Replacement

You don't often get email from [e-mail]. Learn why this is important
[Quoted text hidden]
Stockton Antczak <[e-mail]>Thu, Feb 6, 2025 at 10:34 AM
To: Joshua Hortin <[e-mail]>
Josh,
I have finished my review and now it is passing through the peer review process. I imagine each stage should take a few
days based on how busy people are and how quickly they can get to it but I expect that it should only take a few weeks at
most to get the peer review wrapped up and start preparing the AO.
I do have one quick question about contact information for the site. I sent an email to Morgan about it but I figure I'll ask
you too. We currently have Rob Richards listed as the source contact. I'm assuming that is outdated since I haven't been
in contact with him at all for this project. If you could give me the name, phone number, and email of the person you would
prefer to be listed as the source contact I would appreciate it. We also don't have a billing contact listed. It can be the
same person, but again, I would need a name, phone number, and email for them.
Let me know if you have any other questions.
Thanks,
Stockton
[Quoted text hidden]
Joshua Hortin <[e-mail]>Fri, Feb 14, 2025 at 11:26 AM
To: Stockton Antczak <[e-mail]>
Hey Stockton,
Sorry for the delay, I was running through my inbox and realized I never answered your queson. I don't know if
Morgan got back to you, and if she did hopefully I am not giving you conflicng info. It is ok to leave Rob as both the
client and billing contact. He is the landfill project owner and would pass bills on to the right people. We are the
engineers working on his behalf to resolve the perming needs.
If it's helpful to know, the operaons manager at Intermountain Regional Landfill is a guy named Brian Alba, he is
physically present everyday out there and is doing the hands on work of direcng landfill crews and operaons, and
running the gas collecon and flare system.
2/28/25, 1:50 PM State of Utah Mail - Notice of Intent - Intermountain Regional Landfill Generator Replacement
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1822063882924988561&simpl=msg-f:182206388292498856…3/4
Caution: External
Thanks!
Joshua Hortin, PE
Civil and Environmental Engineer

HANSEN, ALLEN & LUCE
859 W. South Jordan Pkwy. Ste. 200
South Jordan, UT 84095
O: 801.566.5599 | C: 801.668.4265

Click below to learn about HAL’s legacy of serving your community for over 50 years!

From: Stockton Antczak <[e-mail]>
Sent: Thursday, February 6, 2025 10:34 AM
To: Joshua Horn <[e-mail]>
Subject: Re: Noce of Intent - Intermountain Regional Landfill Generator Replacement

[Quoted text hidden]
2/28/25, 1:50 PM State of Utah Mail - Notice of Intent - Intermountain Regional Landfill Generator Replacement
https://mail.google.com/mail/u/0/?ik=15596fcb07&view=pt&search=all&permthid=thread-f:1822063882924988561&simpl=msg-f:182206388292498856…4/4
Cat® XQ35 Rental Generator Set
Page 1 of 7 LEHX0029-07
Image shown may not reflect actual configuration
Specifications
Standby 30 kW, 38 kVA
Prime 27 kW, 35 kVA
U.S. EPA Tier 4 Final
60 Hz
1800 RPM
Generator Frequency Voltage Standby
kW (kVA)
Prime kW
(kVA) Phase Amp (A)
Standard
60 Hz 480/277V 30 (38) 27 (35) 3-phase 40.59
60 Hz 208/120V 30 (38) 27 (35) 3-phase 93.68
60 Hz 240/120V 30 (30) 27 (27) 1-phase 112.5
Optional
60 Hz 600/349V 30 (38) 27 (35) 3-phase 32.48
60 Hz 480/277V 30 (38) 27 (35) 3-phase 40.59
60 Hz 208/120V 26 (33) 24 (30) 3-phase 83.27
60 Hz 240/120V 21 (21) 19 (19) 1-phase 79.17
Cat® C2.2T Diesel Engine Metric Imperial (English)
Configuration I-4, 4-Stroke Diesel
Bore 84 mm 3.3 in
Stroke 100 mm 3.9 in
Displacement 2.2 L 135 in3
Aspiration ATAAC
Compression Ratio 18:1
Engine Speed 1800 rpm
Governor Type Electronic
Governor Class ISO8528 G1
Maximum power at rated speed – bkW (hp)
Standby
Prime
36.4
32.8
(49)
(44)
Cat® XQ35 Rental Generator Set
Page 2 of 7 LEHX0029-07
Benefits & Features
Fuel/Emissions Strategy
•Meets U.S. EPA Tier 4 Final emission standards
and CARB certified for non-road mobile
applications at all 60 Hz ratings
Cat C2.2T Diesel Engine
•Four-stroke diesel engine combines performance
and excellent fuel economy with minimum weight
•On-engine aftertreatment consists of NOx
Reduction System (NRS), Diesel Oxidation
Catalyst (DOC) and Diesel Particulate Filter (DPF)
for service-free operation
•500-hour oil change interval
•Common rail direct injection
•Electronic engine controls
•Engine block heater 110-120 VAC
Cat LC Series Generator
•Matched to the performance and output
characteristics of Cat diesel engines
•Class H Insulation
XQCP Control Panel
•Electronic control panel provides power
metering, protective relaying, engine, and
generator parameter viewing, and expanded AC
metering
•Four lines back-lit LCD text display
•Simple, user-friendly interface and navigation
•Integrates with the Automatic Voltage Regulator
(AVR) to provide precise control, excellent block
loading, and constant voltage
Environmentally Friendly Design
•110% spill containment of all engine fluids
•Nonmetallic fuel tank provides >24-hour run time at
75% prime load
•Two-way valve and external fuel ports to easily
switch between on-board and external fuel source
•Solar battery maintainer
Sound-attenuated Enclosure
•Rugged, corrosion-resistant construction:
–Galvannealed, sheet steel body panels with
zinc phosphate pretreatment prior to polyester
powder coating
–Stainless steel hinges
•Excellent access for service and maintenance:
–Two doors on each side, and one rear door for
power distribution and control panel access
–Lube oil and coolant drains piped to exterior
–of the enclosure
•Security and safety features:
–Control panel located behind rear access door
with safety-glass viewing window
–Padlockable latches on all access doors
–Exterior emergency stop (E-stop) button
Standard Controls and Power Distribution
•Three-position switch for easy selection of
desired output (480/277V 3-phase, 208/120V
3-phase, or 240/120V single phase)
•Controls, sockets, and power distribution all
accessible via rear access door
•Hinged door with safety switch to trip breaker
Asset Monitoring and Management
•Cat Connect hardware provides two-way
communication for remote control and
equipment monitoring via cellular network
•Customer-defined, equipment-based real-time
status updates and alerts
•Flexible and customer-configurable user
interface
•GPS provides asset location and geo-fencing
Options
•Generator anti-condensation heater
•Battery charger
•Trailer (electric, hydraulic, or no brakes)
•Trailer hitch (2-in. ball, 2-5/16-in. ball, or pintle)
•600V generator
Cat® XQ35 Rental Generator Set
Page 3 of 7 LEHX0029-07
Standard Equipment
Engine
•Cat C2.2T, heavy-duty, EPA Tier 4 Final certified NOx
and engine-mounted DOC and DPF
•Block heater, 110-120 VAC
•Requires Ultra Low Sulfur Diesel (ULSD) fuel
•Engine Electrical diesel engine
•System:
–12-volt, DC electrical system
–85-amp, DC charging alternator
–Electronic governor and engine controls
–Oil pressure, coolant temperature, and coolant
level shutdown switches
•Engine Filtration System:
–Cartridge-type air filter with service indicator
–Cartridge-type fuel filter with upstream pre-filter
and water separator,
–Spin-on, full-flow lube oil filter, requires API CJ-4
lube oil.
Generator and Voltage Regulation
•Screen protected and drip-proof (IP23), self-
regulating, 12-lead, 4-pole, brushless generator
•Sealed-for-life bearing
•Electrical design in accordance with IEC60034-1,
EN61000-6, NEMA MG-1.22, and CSA
•Self-excited for self-protection against short circuits
•Voltage selection switch (3 position) mounted to
generator terminal box
–Optional
–Anti-condensation, space heater, 60-Watt,
110-120 VAC
•Insulation System:
–Class H insulation system
–Windings are impregnated in a thermo-setting
moisture, oil, and acid resisting varnish
–Heavy coat of anti-tracking varnish for additional
protection against moisture or condensation
•AVR D350:
–Simplified operation and troubleshooting
–Equipped with NFC technology for
communication and configuration purposes
–Fully supported by Cat ET service tool
•Waveform distortion, THF, and TIF Factors:
–Total distortion of voltage waveform with open
circuit between phases, or phase and neutral,
on the order of 1.7 Total distortion <4%, on a
3-phase, balanced, harmonic-free load
–Total distortion <2%, under no load
–Waveform: NEMA (TIF <50)
–2/3 pitch standard on all stator windings
Generator Set Packaging
•Base frame and containment tray
–Heavy-duty, fabricated steel base frame with
specially designed lifting points
–Spill containment tray mounted to base
frame, with leak-detection switch
•Canopy
–Sound attenuated to 64 dBA at 7 m (23 ft)
–Two doors on each side, and one rear door
for power distribution and control panel
access
•Cooling System:
–Radiator and two-speed, electric cooling fans (2)
complete with protective guards
–Cooling system provides 43°C (109°F)
ambient capability at 500 m (2,460 ft) above
sea level
•Electrical System:
–12-volt, DC electrical system
–850CCA, maintenance-free, wet battery
–Battery disconnect switch, lockable
–Solar battery maintainer with solar array
–Resettable, switch-style circuit breakers (DC
circuit)
–Optional 10A battery charger, 110-120 VAC
constant voltage, UL listed
•Engine and generator mounting
–Engine and generator are directly coupled by
an SAE flange
–Engine flywheel is flexibly coupled to the
generator rotor, with full torsional analysis
completed to ensure no harmful vibration will
occur in the assembly
–Anti-vibration pads between
engine/generator feet and base frame
•Fuel System:
–Cross-linked polyethylene (XLPE) fuel tank;
55-gallon usable volume
–24-hour runtime @ 100% prime load
–2-position valves and external ports (1/4-in.
NPT) allow connection of an auxiliary fuel
source
•CSA 22.2 Certified
Cat® XQ35 Rental Generator Set
Page 4 of 7 LEHX0029-07
Standard Equipment (continued)
Generator Controls and Power Distribution
•XQCP, digital generator set controller, mounted
behind a hinged, lockable door with viewing
window
•Circuit Breaker: 3-pole molded case breaker,
125A, UL- and CSA-listed with shunt trip
•Safety switch on hinged main bus cover – trips
breaker if cover is opened
•Two-wire, remote start-stop terminals
•Customer auxiliary power connections:
–Three – 250V, 50A California-style, NEMA,
twist lock receptacles
–Two – 120V, 20A duplex receptacles with
GFCI*
–Each receptacle is protected by a miniature
circuit breaker, which also acts as an on/off
switch
•Main customer connections:
–Tin-plated copper bus bars with phase
separators, located behind a protective door with
shunt trip switch
–Bus bars sized for full load capacity of generator
set at 0.8 power factor
Quality and Product Support
•Factory load-testing of complete generator set
•Factory test certificate available upon request
•Equipment meets the following standards:
BS4999, BS5000, BS5514, IEC60034, EN61000-
6, NEMA MG-1.22 & CSA
•Full set of operation and maintenance manuals
*Voltage at receptacle is 120V when
switch is in 240/120 and 208 positions,
and 139V in 480V position.
Receptacles are not powered when
600V is selected.
Cat® XQ35 Rental Generator Set
Page 5 of 7 LEHX0029-07
Technical Data
Cat Generator
Frame Size 1514J
Pitch 0.6667
No. of poles 4
Insulation Class H
Enclosure Drip proof IP23
Voltage regulation ± 0.25% at steady state from no load to full load
Frequency regulation ± 0.25% for constant load from no load to full load
Waveform distortion THD <4%
Telephone interference TIF<50, THF<2%
Overspeed limit 2250 rpm
Available voltages
Standard Switchable voltage output: 480/277V, 3-phase;
208/120V, 3-phase; 240/120V, single-phase
Optional Switchable voltage output: 600/349V,
3-phase; 480/277V, 3-phase; 208/120V,
3-phase; 240/120V, single-phase
Cat Generator Set – 1800 rpm/60 Hz
Units Standby Prime
Power Rating kW (kVA) 30 (37.5) 27 (35)
Performance Specification
Lubricating System
Total oil
Capacity oil
L (gal)
L (gal)
10.6 (2.8)
8.9 (2.4)
10.6 (2.8)
8.9 (2.4)
Fuel System
Fuel Consumption** — 100% Load
75% Load
50% Load
Fuel Tank Capacity
L/hr (gal/hr)
L/hr (gal/hr)
L/hr (gal/hr)
L (gal)
9.8 (2.6)
7.4 (2.0)
4.9 (1.3)
208 (55)
8.8 (2.3)
6.7 (1.8)
4.4 (1.2)
208 (55)
Running Time — at 100% Load Hours >20 >24
Cooling System
Radiator system capacity including engine
Heat rejected to coolant at rated power
L (U.S. gal)
kW (Btu/min)
11.5 (3.0)
29.6 (1,685)
11.5 (3.0)
26.6 (1,514)
Air Requirements
Combustion air flow
Radiator cooling air
Generator cooling air
m3/min (cfm)
m3/min (cfm)
m3/min (cfm)
3.3 (116.5)
86.5 (3,023)
19.2 (678)
3.3 (116.5)
86.5 (3,023)
19.2 (678)
Noise Rating**
[with enclosure at 7 meters (23 feet)] dB(A) 64.3 63.9
**Package fuel consumption and sound levels are for reference only.
Cat® XQ35 Rental Generator Set
Page 6 of 7 LEHX0029-07
Technical Data (continued)
Dimensions and Weights
Model Length
mm (in)
Width
mm (in)
Height
mm (in)
With Lube Oil
& Coolant
kg (lb)
With Fuel, Lube
Oil, & Coolant
kg (lb)
XQ35 2318 (91.3) 1050 (41.4) 1617 (63.7) 1003 (2215) 1178 (2600)
XQ35 with trailer
(no brakes) 3454 (136.0) 1687 (66.4) 1883 (74.1) 1154 (2555) 1332 (2940)
XQ35 with trailer
(electric brakes) 3454 (136.0) 1687 (66.4) 1883 (74.1) 1166 (2575) 1341 (2960)
XQ35 with trailer
(hydraulic brakes) 3534 (139.1) 1687 (66.4) 1883 (74.1) 1171 (2585) 1345 (2970)
General Layout Dimensions
Dimensions in millimeters (inches).
Shown with optional trailer.
Cat® XQ35 Rental Generator Set
Control Panel and Power Distribution Layout
Rating Definitions and Conditions
Standby — Output available with varying load for the
duration of the interruption of the normal source
power. Average power output is 70% of the standby
power rating. Typical operation is 200 hours per year,
with maximum expected usage of 500 hours per year.
Prime — Output available with varying load for an
unlimited time. Average power output is 70% of the
prime power rating. Typical peak demand is 100% of
prime rated ekW with 10% overload capability for
emergency use for a maximum of 1 hour in 12.
Overload operation cannot exceed 25 hours per year.
LEHX0029-07 (12/22)
www.Cat.com/rentalpower
©2022 Caterpillar All rights reserved.
Materials and specifications are subject to change without notice. The International System of Units (SI) is used in this publication.
CAT, CATERPILLAR, LET’S DO THE WORK, their respective logos, "Caterpillar Corporate Yellow", the "Power Edge" and Cat “Modern Hex” trade dress as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission.
Item Description
1 Steel enclosure with hinged, lockable door (not
shown)
2 Circuit breakers for receptacles
3 Emergency stop
4 Single-phase GFCI duplex receptacles (20A @120V)
5 Two-wire remote start terminals
6
Single-phase, California-style, twist-lock
receptacles, 50A @208V phase-to-phase, 120V
phase to neutral, or 240/120 V single phase when
in that voltage position
7
Single-phase NEMA locking input receptacle
(30A @120V) to power optional block heater,
battery charger, and generator space heater
8 Glow plug lamp
9 DPF and Regen Active Lamp
10 Emission System Failure Lamp
11 XQCP digital generator set controller
12 Potentiometer for voltage adjustment
13 Cat ET service tool connector
14 Circuit breaker, 3-pole molded case, 125A
15 Main bus connection (bus bars attached to breaker)
behind door and viewing window
16 Bus bar viewing window w/phase diagram film
17 Quarter-turn door lock
18 Breaker trip door switch
16
15
14
13
11
10
9
8
7
2
1
6
4
18
3
5
17
12
SALT LAKE AREA OFFICE
859 W SOUTH JORDAN PKWY, STE 200
SOUTH JORDAN, UTAH 84095
PHONE: [phone]
www.HALengineers.com

E N G I N E E R I N G E X C E L L E N C E S I N C E 1 9 7 4

Mr. Stockton Antczak January 23, 2025
Utah Department of Environmental Quality – Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84114-4880

RE: Intermountain Regional Landfill (IRL) – Notice of Intent: Generator Replacement

Mr. Antczak,

On behalf of ROC Fund Landfill Holdings, LLC (Intermountain Regional Landfill), Hansen, Allen
& Luce (HAL) is submitting notification of an upcoming replacement of the generators for
operating the flare at their Class V facility located in Utah County, Utah within the Northwest
corner of Section 16 of Township 7 South, Range 2 West Salt Lake Base and Meridian.

The C70D2RE Cummins Diesel Gensets at Intermountain Regional Landfill (IRL) which currently
power the landfill gas collection and control system (LGCS) are the original system generators
and are rated at 70 kW (94 hp). The Cummins generators require a much larger workload than
the LGCS flare and blowers need in order to run efficiently and effectively. The lack of power load
to the Cummins generators has caused them to have multiple issues regarding temperature,
aftertreatment system issues, sudden shutdowns, and overall unreliability to continue to operate
and power the flare skid. The unreliability of the Cummins generators threatens IRL’s ability to
comply with multiple sections of its Title V permit, particularly II.B.2.b.(h)(ii) and II.B.2.c. Therefore,
IRL has decided to transition to two smaller CAT generators, which are more adequately sized to
handle the amount of power at the flare skid.

The current two generators (C70D2RE Cummins Diesel Genset) are being replaced with two
XQ35 CAT diesel generators (30 kW, 2.2 L displacement, serial numbers: CG501084 and
CG501169). These generators are of a smaller size, have a smaller workload capacity and are
better suited for the amount of power needed for the flare skid. They are also estimated to produce
fewer emissions (maximum diesel consumption of 2.6 gal/hr versus 8 gal/hr) as shown in the
attached emissions inventory, and the new generators meet Tier IV emission standards like the
old generators. This change is primarily expected to affect only II.A.4 of the Title V permit.

Please contact us with any questions or comments regarding the information contained herein.

Sincerely,

________________________________
Andrew Alvaro
Environmental Services Director

CLIENT: Intermountain Regional Landfill SHEET 1 OF 3
PROJECT: General Compliance and Permitting COMPUTED: JMH
FEATURE: Emissions Comparison CHECKED: AJA
PROJECT NO.: 373.08.204 DATE: Jan 2025

Purpose: To compare the estimated emissions of C70D2RE Cummins Diesel
Generators and XQ35 CAT Diesel Generators.

Process: Assumptions: It is assumed that the 30 kW XQ35 CAT diesel generators and
the 70 kW C70D2RE Cummins diesel generators fall into the same generator
category in the State and Local Emissions Inventory System (SLEIS) and
therefore the same emission factors apply.

In 2023, the Cummins generators used a combined 24,960 gallons of diesel
fuel. Per the Title V permit conditions, only one generator is used at a time
but one of the generators runs 24 hours per day to power the landfill gas
collection and control system.

(24,960 gallons of diesel fuel per year)/(365 days/year)/(24 hours/day) = 2.85
gallons of diesel fuel per hour

The following figure is from the specifications for the Cummins generator:

Interpolating between ¼ load and ½ load, 2.85 gallons of diesel fuel per hour
equates to a load of 33.1%, which is equivalent to (0.331)(70 kW) = 23.2 kW.

(2.85 gal/hr – 2.3 gal/hr)*(0.5-0.25 load)/(4.0-2.3 gal/hr)+0.25 load = .331 load

A load of 23.2 kW on a 30 kW generator is (23.2 kW)/(30 kW) = 77.3% load.

The following figure is from the specifications for the CAT generator:

CLIENT: Intermountain Regional Landfill SHEET 2 OF 3
PROJECT: General Compliance and Permitting COMPUTED: JMH
FEATURE: Emissions Comparison CHECKED: AJA
PROJECT NO.: 373.08.204 DATE: Jan 2025

Using the higher (standby) fuel consumption, and interpolating between 75%
and 100% load, the fuel consumption is expected to be 2.06 gal/hr.

(0.023)*(2.6-2 gal/hr)/(1-0.75)+2 gal/hr = 2.06 gal/hr

This fuel consumption rate equates to (2.06 gal/hr)*(24 hr/day)*(365
day/year) = 18,100 gal/year.

The following table is from the SLEIS:

The emissions were calculated from the emission factors shown above with
the units being 1,000 gallons.

i.e., PM10 = (18.1 kgal)*(42.47 lb/kgal)*(1 ton/2000 lb)

Pollutant Fuel (1000 gal) Emission Factor
(lb/1000 gal)
Estimated annual
tonnage emitted
PM10 18.1 42.47 0.384
PM2.5 18.1 42.47 0.384
SO2 18.1 39.73 0.360
NOX 18.1 604.17 5.468
VOC 18.1 49.32 0.446
CO 18.1 130.15 1.178

CLIENT: Intermountain Regional Landfill SHEET 3 OF 3
PROJECT: General Compliance and Permitting COMPUTED: JMH
FEATURE: Emissions Comparison CHECKED: AJA
PROJECT NO.: 373.08.204 DATE: Jan 2025

Results: The comparison of the emissions from the combined usage of two CAT
generators versus the emissions from the 2023 combined usage of two
Cummins generators are shown in the following table.

Pollutant
Cummins Generators
(tons/year)
CAT Generators
(tons/year)
PM10 0.530 0.384
PM2.5 0.530 0.384
SO2 0.496 0.360
NOX 7.540 5.468
VOC 0.616 0.446
CO 1.624 1.178

It is estimated that the overall emissions will decrease by about 27%, in line
with the decrease in fuel usage.