DAQ-2025-003080

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DAQC-592-25
Site ID 15975 (B1)

MEMORANDUM

TO: FILE – CITY OF LOGAN NORTH VALLEY LANDFILL

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Haynes, Environmental Scientist

DATE: June 23, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Cache County,
FRS ID# UT0000004900500105

INSPECTION DATE: June 19, 2025

SOURCE ADDRESS: The source is not located as stated in the Title V permit. Refer to the
NOI, public notices, and this memorandum for the correct location.

14,200 Stink Creek Road
North Clarkston, UT 84305

From Hwy 142 in Clarkston, travel east on Center Street about 1/2 mile
to Harts Gravel Road (8100 West). Continue north on this road for
roughly 6.9 miles until this paved road dead ends at the landfill. The road
will bend 90 degrees left, becoming 11,800 North, then bend 90 degrees
right, onto Stink Creek Road, and dead end at the landfill. Furthermore,
map directions to the landfill may take a different route from Clarkston –
north on 8600 West to Stink Creek Road. Parts of this road are dirt and
may be impassable from snow pack or when wet.

MAILING ADDRESS: 153 North 1400 West
Logan, Utah 84321

SOURCE CONTACT(S): Tyler Richards, Environmental Engineer: [phone]
Warren Hullinger, Landfill Manager: (435)-716-9798
David Andreasen, Foreman: [phone]

OPERATING STATUS: Not operating

PROCESS DESCRIPTION: Logan City operates a municipal solid waste (MSW) landfill outside of
Clarkston, UT, in Cache County. The facility accepts municipal and
commercial waste. No gas collection system is required at this facility.

APPLICABLE
REGULATIONS: Title V Operating Permit 500105002 issued October 28, 2024.

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SOURCE INSPECTION EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A 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". (R307-415-6b)

Status: The permit is federally enforceable.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. The landfill appeared to be operating in compliance at the time of inspection
and records review. See the status of each condition below for details.

I.C Duty to Comply.

I.C.1 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(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 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 furnish 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
confidentiality. (R307-415-6a(6)(e))

I.C.4 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(6)(c))

Status: In compliance. The permittee appeared to be operating in compliance with the current permit
at the time of inspection and review of records. All requested information was provided.
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I.D Permit Expiration and Renewal.

I.D.1 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))

I.D.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(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.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. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In Compliance. This permit has not expired.

I.E 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 renewal application. In 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))

Status: In Compliance. The current permit went into effect October 28, 2024. Application for the next
renewal is due by April 28, 2029.

I.F 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))

Status: In Compliance. No portion of the permit is being challenged.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

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I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. Emission fees have been paid as invoiced.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: In Compliance. This permit does not convey property rights of any sort or any exclusive
privilege.

I.I 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. (R307-415-6a(8))

Status: This is not an inspection item.

I.J Inspection and Entry.

I.J.1 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:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

I.J.2 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(2)(e))

Status: In compliance. Access to the facilities and records was granted for this inspection.

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I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification 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 formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All forms, reports, and compliance certifications appear to contain the
certification statement.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
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(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b 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 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c 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 intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify 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

I.L.1.d Such other facts as the Director may require to determine the compliance status.

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I.L.2 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: (R307-415-
6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance. The most recent annual compliance certification was received April 14, 2025.
This report was evaluated under separate cover and found to meet the requirements of this
condition.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b 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)(a)(xiii) and Section 19-2-
110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)). [R307-
415-6f]

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: A permit shield has not been granted for any specific requirement.

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I.N Reserved.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: This is not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: This is not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: This is not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: This is not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring 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, report, 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(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

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I.S.1.b.4 The analytical techniques or methods used.
I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b 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(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, 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 R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a 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 Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

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I.S.3.b All reports, notifications or other submissions required by this permit 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 certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records were kept as required. Semi-annual monitoring reports have been
submitted as required.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a 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. (R307-415-7g(1)(a))

I.T.1.b 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. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d 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(1)(e))

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I.T.2 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-
7g(1)(b))

I.T.3 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. (R307-415-7g(2))

Status: Not evaluated. Permit reopening is handled by the DAQ engineering section.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance. Emission inventories have been submitted as required.

I.V Title IV and Other, More Stringent 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(1)(b))

Status: This is not an inspection item.
SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 MSW Landfill
Approximately 133 acres Municipal Solid Waste (MSW) Landfill.

II.A.3 Leachate Pond
Leachate generated from the landfill is directed through piping to the leachate collection pond. No unit-
specific applicable requirements.

II.A.4 Misc. Tanks
Includes a propane-fired backup generator, a propane-fired infrared tube heater, propane above ground
storage tanks, and a diesel above ground storage tank. No unit-specific applicable requirements.

Status: In compliance. No unapproved equipment was observed during this inspection.

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II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on MSW Landfill

II.B.1.a Condition:

(1) Opacity caused by fugitive dust shall not exceed:

(a) 10% at the property boundary; and

(b) 20% on site.

(2) The permittee shall submit a fugitive dust control plan to the director in accordance with R307-309-6.

(3) Opacity requirements shall not apply when the wind speed exceeds 25 miles per hour if the owner or
operator has implemented, and continues to implement, the accepted fugitive dust control plan and
administers one or more of the following contingency measures:

(a) Pre-event watering;

(b) Hourly watering;

(c) Additional chemical stabilization;

(d) Cease or reduce fugitive dust producing operations to the extent practicable.

(4) Wind speed shall be measured by an anemometer

(5) Any person responsible for construction or maintenance of any existing road or having right-of-way
easement or possessing the right to use the same, whose activities results in fugitive dust from the
road, shall minimize fugitive dust to the maximum extent possible and in accordance with R307-309-
6.
(6) Unpaved Roads. Any person responsible for construction or maintenance of any new or existing
unpaved road shall prevent, the maximum extent possible, the deposit of material from the unpaved
road onto any intersecting paved road during construction or maintenance. Any person who deposits
materials that may create fugitive dust on a public or private paved road shall clean the road
promptly.

[Origin R307-309-5, R307-309-9]. [R307-309-5, R307-309-9]

II.B.1.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, adherence to the current fugitive dust
control plan approved by the Director shall be monitored to demonstrate that appropriate
measures are being taken to control fugitive dust.

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II.B.1.a.2 Recordkeeping:

A copy of the fugitive dust control plan shall be maintained on-site. Records of measures taken to
control fugitive dust shall be maintained to demonstrate adherence to the most recently approved
fugitive dust control plan. Records shall be maintained as described in Provision I.S.1 of this
permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The latest fugitive dust control plan was reviewed, as well as the most recent water
records.

II.B.1.b Condition:

The permittee shall comply with all applicable requirements in 40 CFR 60, Subpart XXX - Standards of
Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or
Modification After July 17, 2014.

(a) The permittee shall calculate a nonmethane organic compounds (NMOC) emission rate for the
landfill using the procedures specified in 40 CFR 60.764. [Origin: 40 CFR 60.762(b)]

(1) If the calculated NMOC emission rate is less than 34 megagrams per year, the permittee shall:

(i) Submit an annual NMOC emission report to the Director, except as provided for in 40 CFR
60.767(b)(1)(ii) [Origin: 40 CFR 60.762(b)(1)(i)]; and

(ii) Recalculate the NMOC emission rate annually using the procedures specified in 40 CFR
60.764(a)(1) until such time as the calculated NMOC emission rate is equal to or greater than
34 megagrams per year, or the landfill is closed [Origin: 40 CFR 60.762(b)(1)(ii)].

(A) If the calculated NMOC emission rate, upon initial calculation or annual recalculation is
equal to or greater than 34 megagrams per year, the permittee must either: comply with
paragraph (a)(2) below; calculate NMOC emissions using the next higher tier in 40 CFR
60.764; or conduct a surface emission monitoring (SEM) demonstration using the
procedures specified in 40 CFR 60.764(a)(6). [Origin: 40 CFR 60.762(b)(1)(ii)(A)].

(2) If the calculated NMOC emission rate is equal to or greater than 34 megagrams per year using
Tier 1, 2, or 3 procedures, the permittee shall either:

(i) Submit a collection and control system design plan prepared by a professional engineer to the
Director within 1 year as specified in 40 CFR 60.767(c) or (d);

(ii) calculate NMOC emissions using the next higher tier in 40 CFR 60.764;

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(iii) or conduct a surface emission monitoring demonstration using the procedures specified in 40
CFR 60.764(a)(6). The collection and control system shall meet the requirements of 40 CFR
60.762(b)(2)(ii) and (iii). [Origin: 40 CFR 60.762(b)(2)(i)]

(b) When the MSW landfill is closed, the permittee is no longer subject to the requirement to maintain an
operating permit under 40 CFR Part 70 for the landfill if the landfill is not otherwise subject to the
requirements of 40 CFR Part 70 and if either of the following conditions are met:

(1) The landfill was never subject to the requirement for a control system under paragraph (a)(2)
above. [Origin: 40 CFR 60.762(d)(1)]; or

(2) The permittee meets the conditions for control system removal specified in 40 CFR
60.762(b)(2)(v).

[Origin: 40 CFR 60.762(b), 40 CFR 60.762(d)]. [40 CFR 60 Subpart XXX]

II.B.1.b.1 Monitoring:

The permittee shall monitor the NMOC emission rate by using the equations in 40 CFR 60.764
and following the four tiers process outlined in 40 CFR 60.764.

(a) The permittee shall calculate the NMOC emission rate using either Equation 1 or Equation 2
of 40 CFR 60.764.

(b) Tier 1. The permittee shall compare the calculated NMOC mass emission rate to the standard
of 34 megagrams per year. [40 CFR 60.764(a)(2)]

(1) If the NMOC emission rate calculated in paragraph (a) above, is less than 34 megagrams
per year, then the permittee shall submit an NMOC emission rate report according to 40
CFR 60.767(b), and shall recalculate the NMOC mass emission rate annually as required
by 40 CFR 60.762(b). [40 CFR 60.764(a)(2)(i)]

(2) If the calculated NMOC emission rate is equal to or greater than 34 megagrams per year
as calculated by paragraph (a) above, then the permittee shall either:

(i) Submit a gas collection and control system design plan within 1 year as specified in
40 CFR 60.767(c) and install and operate a gas collection and control system within
30 months according to 40 CFR 60.762(b)(2)(ii) and (iii),

(ii) Determine a site specific NMOC concentration and recalculate the NMOC emission
rate using the Tier 2 procedures provided in paragraph (c) below, or

(iii) Determine a site-specific methane generation rate constant and recalculate the
NMOC emission rate using the Tier 3 procedures provided in paragraph (d) below.
[40 CFR 60.764(a)(2)(ii)]

(c) Tier 2. The permittee shall determine the site-specific NMOC concentration using the
sampling procedures described in 40 CFR 60.764(a)(3).

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(1) Within 60 days after the date of completing each performance test (as defined in 40 CFR
60.8), the permittee shall submit the results according to 40 CFR 60.767(i)(1). [40 CFR
60.764(a)(3)(i)]

(2) The permittee shall recalculate the NMOC mass emission rate using Equation 1 or
Equation 2 provided in 40 CFR 60.674 and using the average site-specific NMOC
concentration from the collected samples instead of the default value provided in 40 CFR
60.674. [40 CFR 60.764(a)(3)(ii)]

(3) If the resulting NMOC mass emission rate is less than 34 megagrams per year, then the
permittee shall submit a periodic estimate of NMOC emissions in an NMOC emission
rate report according to 40 CFR 60.767(b)(1), and shall recalculate the NMOC mass
emission rate annually as required under 40 CFR 60.762(b). The site-specific NMOC
concentration must be retested every 5 years using the methods specified in 40 CFR
60.764. [40 CFR 60.764(a)(3)(iii)]

(4) If the NMOC mass emission rate as calculated using the Tier 2 site-specific NMOC
concentration is equal to or greater than 34 megagrams per year, the permittee shall
either:

(i) Submit a gas collection and control system design plan within 1 year as specified in
40 CFR 60.767(c) and install and operate a gas collection and control system within
30 months according to 40 CFR 60.762(b)(2)(ii) and (iii);

(ii) Determine a site-specific methane generation rate constant and recalculate the
NMOC emission rate using the site-specific methane generation rate using the Tier 3
procedures specified in paragraph (d) below; or

(iii) Conduct a surface emission monitoring demonstration using the Tier 4 procedures
specified in paragraph (f) below. [40 CFR 60.764(a)(3)(iv)(A)-(C)].

(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 either Equation1 or Equation 2 in 40 CFR 60.764 and using
a site specific methane generation rate constant k, and the site specific NMOC concentration
as determined in paragraph (c) above instead of the default values provided in 40 CFR
60.764. The permittee shall compare the resulting NMOC mass emission rate to the standard
of 34 megagrams per year. [40 CFR 60.764(a)(4)]

(1) If the NMOC mass emission rate as calculated using the Tier 2 site-specific NMOC
concentration and Tier 3 site-specific methane generation rate is equal to or greater than
34 megagrams per year, the permittee shall either:

(i) Submit a gas collection and control system design plan within 1 year as specified in
40 CFR 60.767(c) and install and operate a gas collection and control system within
30 months according to 40 CFR 60.762(b)(2)(ii) and (iii); or

(ii) Conduct a surface emission monitoring demonstration using the Tier 4 procedures
specified in paragraph (f) below. [40 CFR 60.764(a)(4)(i)(A)-(B)]

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(2) If the NMOC mass emission rate is less than 34 megagrams per year, then the permittee
must recalculate the NMOC mass emission rate annually using Equation 1 or Equation 2
provided in 40 CFR 60.764 and using the site-specific Tier 2 NMOC concentration and
Tier 3 methane generation rate constant and submit a periodic NMOC emission rate
report as provided in 40 CFR 60.767(b)(1). The calculation of the methane generation
rate constant is performed only once, and the value obtained from this test must be used
in all subsequent annual NMOC emission rate calculations. [40 CFR 60.754(a)(4)(ii)]

(e) Other methods. The permittee may use other methods to determine the NMOC
concentration or a site-specific methane generation rate constant as an alternative to the
methods required in paragraphs (c) and (d) above if the method has been approved by the
EPA Administrator. [40 CFR 60.764(a)(5)].

(f) Tier 4. The permittee shall demonstrate that surface methane emissions are below 500 parts
per million. Surface emission monitoring shall be conducted on a quarterly basis using the
following procedures. Tier 4 is allowed only if the permittee can demonstrate that NMOC
emissions are greater than or equal to 34 Mg/yr but less than 50 Mg/yr using Tier 1 or Tier 2.
If both Tier 1 and Tier 2 indicate NMOC emissions are 50 Mg/yr or greater, then Tier 4
cannot be used. [40 CFR 60.764(a)(6)]

(i) The permittee shall measure surface concentrations of methane along the entire perimeter
of the landfill and along a pattern that traverses the landfill at no more than 30-meter
intervals using an organic vapor analyzer, flame ionization detector, or other portable
monitor meeting the specifications provided in 40 CFR 60.765(d). [40 CFR
60.764(a)(6)(i)]

(ii) The background concentration shall be determined by moving the probe inlet upwind
and downwind at least 30 meters from the waste mass boundary of the landfill [40 CFR
60.764(a)(6)(ii)]

(iii) Surface emission monitoring shall be performed in accordance with section 8.3.1 of
Method 21 of appendix A of 40 CFR Part 60, except that the probe inlet must be placed
no more than 5 centimeters above the landfill surface; the constant measurement of
distance above the surface should be based on a mechanical device such as with a wheel
on a pole, except as described in paragraph (A) below. [40 CFR 60.764(a)(6)(iii)]

(A) The permittee shall use a wind barrier, similar to a funnel, when onsite average wind
speed exceeds 4 miles per hour or 2 meters per second or gust exceeding 10 miles per
hour. Average on-site wind speed must also be determined in an open area at 5-
minute intervals using an on-site anemometer with a continuous recorder and data
logger for the entire duration of the monitoring event. The wind barrier must
surround the surface emissions monitor (SEM), and must be placed on the ground, to
ensure wind turbulence is blocked. SEM cannot be conducted if average wind speed
exceeds 25 miles per hour. [40 CFR 60.764(a)(6)(iii)(A)]

(B) Landfill surface areas where visual observations indicate elevated concentrations of
landfill gas, such as distressed vegetation and cracks or seeps in the cover, and all
cover penetrations must also be monitored using a device meeting the specifications
provided in 40 CFR 60.765(d). [40 CFR 60.764(a)(6)(iii)(B)]

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(iv) The permittee seeking to comply with the Tier 4 provisions in paragraph (f) of this
Monitoring section must maintain records of surface emission monitoring as provided in
40 CFR 60.768(g) and submit a Tier 4 surface emissions report as provided in 40 CFR
60.767(c)(4)(iii). [40 CFR 60.764(a)(6)(iv)].

(v) If there is any measured concentration of methane of 500 parts per million (ppm) or
greater from the surface of the landfill, the permittee shall submit a gas collection and
control system design plan within 1 year of the first measured concentration of methane
of 500 ppm or greater from the surface of the landfill according to 40 CFR 62.16714(b)
and (c) within 30 months of the most recent NMOC emission rate report in which the
NMOC emission rate equals or exceeds 34 megagrams per year based on Tier 2.

(vi) If after four consecutive quarterly monitoring periods at a landfill, other than a closed
landfill, there is no measured concentration of methane of 500 ppm or greater from the
surface of the landfill, the permittee shall continue quarterly surface emission monitoring
using the methods specified in 40 CFR 60.674.

II.B.1.b.2 Recordkeeping:

(a) The permittee shall maintain records required under 40 CFR Part 60.768, as they apply.

(b) Site-specific surface methane emissions demonstration. The permittee seeking to
demonstrate that site-specific surface methane emissions are below 500 parts per million by
conducting surface emission monitoring under the Tier 4 procedures specified in 40 CFR
60.764(a)(6) shall keep for at least 5 years up-to-date, readily accessible records of all surface
emissions monitoring and information related to monitoring instrument calibrations
conducted according to sections 8 and 10 of Method 21 of appendix A of 40 CFR Part 60,
including all of the following items:

(1) Calibration records:

(i) Date of calibration and initials of operator performing the calibration.

(ii) Calibration gas cylinder identification, certification date, and certified concentration.

(iii) Instrument scale(s) used.
(iv) A description of any corrective action taken if the meter readout could not be
adjusted to correspond to the calibration gas value.

(v) If the permittee makes their own calibration gas, a description of the procedure used.

(2) Digital photographs of the instrument setup, including the wind barrier. The photographs
must be time and date-stamped and taken at the first sampling location prior to sampling
and at the last sampling location after sampling at the end of each sampling day, for the
duration of the Tier 4 monitoring demonstration.

17

(3) Timestamp of each surface scan reading:

(i) Timestamp should be detailed to the nearest second, based on when the sample
collection begins.

(ii) A log for the length of time each sample was taken using a stopwatch (e.g., the time
the probe was held over the area).

(4) Location of each surface scan reading. The permittee must determine the coordinates
using an instrument with an accuracy of at least 4 meters. Coordinates must be in decimal
degrees with at least five decimal places.

(5) Monitored methane concentration (parts per million) of each reading.

(6) Background methane concentration (parts per million) after each instrument calibration
test.

(7) Adjusted methane concentration using most recent calibration (parts per million).

(8) For readings taken at each surface penetration, the unique identification location label
matching the label specified in 40 CFR 60.768(d).

(9) Records of the operating hours of the gas collection system for each destruction device.
[40 CFR 60.768(g)]

(c) Electronic records. Any records required to be maintained by 40 CFR Part 60, Subpart
XXX that are submitted electronically via the EPA's CDX may be maintained in electronic
format. [40 CFR 60.768(i)]

(d) Leachate or liquids addition. The permittee reporting leachate or other liquids addition
under paragraph (c) of Reporting shall keep records of any engineering calculations or
company records used to estimate the quantities of leachate or liquids added, the surface
areas for which the leachate or liquids were applied, and the estimates of annual waste
acceptance or total waste in place in the areas where leachate or liquids were applied. [40
CFR 60.768(j)]

Results of monitoring shall also be maintained in accordance with provision I.S.1 of this
permit.

II.B.1.b.3 Reporting:

(a) NMOC emission rate report. The permittee shall submit an NMOC emission rate report
following the procedure specified in 40 CFR 60.767(i)(2) to the Director initially and
annually thereafter, except as provided for in 40 CFR 60.767(b)(1)(ii). The Director may
request such additional information as may be necessary to verify the reported NMOC
emission rate. [40 CFR 60.767(b)]

(1) The NMOC emission rate report must contain an annual or 5-year estimate of the NMOC
emission rate calculated using the formula and procedures provided in 40 CFR 60.764(a)
or (b), as applicable. [40 CFR 60.767(b)(1)]
18

(i) If the estimated NMOC emission rate as reported in the annual report to the Director
is less than 34 megagrams per year in each of the next 5 consecutive years, the
permittee may elect to submit, following the procedure specified in 40 CFR
60.767(i)(2), an estimate of the NMOC emission rate for the next 5-year period in
lieu of the annual report. This estimate must 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 must be provided to the Director. This estimate must 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 must be submitted to the Director. The revised estimate must cover the 5-
year period beginning with the year in which the actual waste acceptance rate
exceeded the estimated waste acceptance rate. [40 CFR 60.767(b)(1)(ii)]

(2) The NMOC emission rate report must include all the data, calculations, sample reports
and measurements used to estimate the annual or 5-year emissions. [40 CFR
60.767(b)(2)]

(3) The permittee subject to the requirements of this condition is exempted from the
requirements to submit an NMOC emission rate report, after installing a collection and
control system that complies with 40 CFR 60.762(b)(2), during such time as the
collection and control system is in operation and in compliance with 40 CFR 60.763 and
40 CFR 60.765. [40 CFR 60.767(b)(3)]

(b) Electronic reporting. The permittee shall submit reports electronically according to 40 CFR
60.767(i)(1) and (2).

(c) Liquids addition. The permittee of an affected landfill with a design capacity equal to or
greater than 2.5 million megagrams and 2.5 million cubic meters that has employed leachate
recirculation or added liquids based on a Research, Development, and Demonstration permit
(issued through Resource Conservation and Recovery Act, subtitle D, part 258) within the
last 10 years must submit to the Director, annually, following the procedure specified in 40
CFR 60.767(i)(2), the following information:

(1) Volume of leachate recirculated (gallons per year) and the reported basis of those
estimates (records or engineering estimates).

(2) Total volume of all other liquids added (gallons per year) and the reported basis of those
estimates (records or engineering estimates).

(3) Surface area (acres) over which the leachate is recirculated (or otherwise applied).

(4) Surface area (acres) over which any other liquids are applied.

(5) The total waste disposed (megagrams) in the areas with recirculated leachate and/or
added liquids based on on-site records to the extent data are available, or engineering
estimates and the reported basis of those estimates.

(6) The annual waste acceptance rates (megagrams per year) in the areas with recirculated
leachate and/or added liquids, based on on-site records to the extent data are available, or
engineering estimates.
19

(7) The initial report must contain items in paragraph (c)(1) through (6) above per year for
the initial annual reporting period as well as for each of the previous 10 years, to the
extent historical data are available in on-site records, and the report must be submitted no
later than:

(i) September 27, 2017, for landfills that commenced construction, modification, or
reconstruction after July 17, 2014 but before August 29, 2016 containing data for the
first 12 months after August 29, 2016; or

(ii) Thirteen (13) months after the date of commenced construction, modification, or
reconstruction for landfills that commence construction, modification, or
reconstruction after August 29, 2016 containing data for the first 12 months after
August 29, 2016.

(8) Subsequent annual reports must contain items in paragraph (c)(1) through (6) above for
the 365-day period following the 365-day period included in the previous annual report,
and the report must be submitted no later than 365 days after the date the previous report
was submitted.

(9) Landfills may cease annual reporting of items in paragraphs (c)(1) through (7) above
once they have submitted the closure report in 40 CFR 60.767(e). [40 CFR 60.767(k)]

(d) Tier 4 notification.

(1) The permittee of an affected landfill with a design capacity equal to or greater than 2.5
million megagrams and 2.5 million cubic meters shall provide a notification of the date(s)
upon which it intends to demonstrate site-specific surface methane emissions are below
500 parts per million methane, based on the Tier 4 provisions of 40 CFR 60.674(a)(6).
The landfill must also include a description of the wind barrier to be used during the
SEM in the notification. Notification must be postmarked not less than 30 days prior to
such date.

(2) If there is a delay to the scheduled Tier 4 SEM date due to weather conditions, including
not meeting the wind requirements in 40 CFR 60.764(a)(6)(iii)(A), the permittee of a
landfill shall notify the Director by email or telephone no later than 48 hours before any
delay or cancellation in the original test date, and arrange an updated date with the
Director by mutual agreement. [40 CFR 60.767(l)]

(e) There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance. Tier 2 monitoring was performed in November 2021 and reported to DAQ. Five
years of estimated NMOC emissions were included and reported 10.0 Mg estimated emissions in
calendar year 2021. Emissions are estimated to reach 26.2 Mg in calendar year 2025. The company
is planning on performing the next test in 2026.

20

II.C Emissions Trading.
(R307-415-6a(10))
Not applicable to this source.

II.D Alternative Operating Scenarios.
R307-415-6a(9))

Not applicable to this source.

EMISSION INVENTORY: The latest Emissions Inventory was submitted to SLEIS on April 29,
2024, for reporting year 2023:
Pollutant Tons/yr
PM10 4.086
PM2.5 0.571
NOx 2.917
SO2 0.004
VOC 18.41
CO 1.267

PREVIOUS ENFORCEMENT
ACTIONS: None during the previous five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: City of Logan North Valley Landfill should be considered in compliance
with the Title V conditions evaluated during this inspection.

HPV STATUS: Not Applicable

COMPLIANCE
ASSISTANCE: None

RECOMMENDATION
FOR NEXT INSPECTION: Follow directions to the landfill found in source address above.

ATTACHMENT: VEO Form