DAQ-2025-003959

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DAQC-750-25
Site ID 15792 (B1)

MEMORANDUM

TO: FILE – ROC – Intermountain Regional MSW Landfill (IRL)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Randolph, Environmental Scientist

DATE: August 4, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Utah County,
FRS #UT0000004904900334

INSPECTION DATE: July 17, 2025

SOURCE LOCATION: 800 South Allen Ranch Road, Fairfield, UT 84013

From Fairfield take a left onto Allen Range Road and another left onto
800 South. The facility is on the right side of the road about a half mile
down.

MAILING ADDRESS: Corporate Office:
ROC – Intermountain Regional MSW Landfill
1220 North 500 West, Suite 102, Lehi, UT 84043

SOURCE CONTACTS: Robert Richards, General Manager: [phone]
Brian Alba, Operations Manager: [phone]
[e-mail]
Hansen, Allen and Luce Inc., (HAL Inc.): [phone]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: ROC - Intermountain Regional Landfill is a municipal solid waste
(MSW) landfill. The facility accepts municipal and commercial solid
waste. The waste material is brought to the landfill by trucks and trailers.
There are designated areas in the landfill for various classes of waste.
After dumping, the waste material is compacted by heavy equipment that
rolls over the material as it levels and spreads the waste material. Most
waste material is inspected prior to entering the landfill area. When the
waste material reaches the required depth, soil is spread over the material
to a required depth to seal the dump area. After the dump is sealed it is
seeded to control fugitive dust. Water is used if needed to control visible
emissions.

JR

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APPLICABLE
REGULATIONS: Title V Operating Permit 4900334002, dated December 20, 2023, and
revised April 23, 2025.
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Cc: Emission Guidelines and Compliance Times for
Municipal Solid Waste Landfills
NSPS (Part 60), WWW: Standards of Performance for Municipal Solid
Waste Landfills
NSPS (Part 60), XXX: Standards of Performance for Municipal Solid
Waste Landfills That Commenced Construction, Reconstruction, or
Modification After July 17, 2014
NSPS (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
NESHAP (Part 63) AAAA: National Emissions Standards for Hazardous
Air Pollution Municipal Solid Waste Landfills
NSPS (Part 60) IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines

SOURCE
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: This is a statement of fact and not an inspection item.

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: This is a statement of fact and not an inspection item.

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))

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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: This is a statement of fact and not an inspection item.

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 – The permit expires December 20, 2028. Application for renewal is
due June 20, 2028.
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: Application for renewal is due June 20, 2028.

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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: This is a statement of fact and not an inspection item.

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))

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 – The annual emission fee was 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: This is a statement of fact and not an inspection item.

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 a statement of fact and 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))

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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 – Required records were made available and no claims of
confidentiality were made at time of the inspection.

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 – Reports and certifications that were submitted appeared to have
certification statements and were signed by responsible officials.

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

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I.L.1.d Such other facts as the Director may require to determine the compliance status.
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 Annual Title V Monitoring/Compliance Report was submitted
March 6, 2025 (due March 30, 2025).

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)(g) and Section 19-2-110 prior
to or at the time of issuance of this permit. (R307-415-6f(3)(b))

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: N/A – See section III of the permit.

I.N Reserved.

I.O Operational Flexibility.

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

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I.P Off-permit Changes.

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

I.Q Administrative Permit Amendments.

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

I.R Permit Modifications.

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

Status: These are statements of facts and not inspection items (I.O through I.R).

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.

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.

Status: In compliance – Required records were provided at time of the inspection.

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))

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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]

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. Semi-annual monitoring reports have been submitted as required
(reviewed by DAQ staff) and are in main source file.

I.T Reopening for Cause.

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

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SECTION II: SPECIAL PROVISIONS

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

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))

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: This is a statement of fact and not an inspection item.

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 – The 2023 emission inventory was received April 11, 2024. See the
SLEIS database.

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 a statement of fact and not an inspection item.

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II.A.1 Permitted Source
Source-wide

II.A.2 Landfill: MSW Landfill (designated as Landfill)
Class V Sanitary Landfill with a 15.4 million Mg capacity and a gas collection and
control system (GCCS). The GCCS, designed in accordance with 40 CFR 60 Subpart
WWW, is controlled by a candlestick flare. The landfill was opened in 2012. 40 CFR 62
Subpart OOO and 40 CFR 63 Subpart AAAA apply to this unit.

II.A.3 Candlestick Flare
One (1) candlestick flare that combusts collected landfill gas.

II.A.4 Flare Station Generator Engines
Two (2) Compression Ignition Reciprocating Internal Combustion Engines (CI RICE)
that power the landfill gas blower system. Each engine is individually rated at 30 kW
(40.2 hp). Subject to 40 CFR 60 Subpart IIII.

Status: In compliance – The only equipment required to be listed in this condition is the landfill’s
gas collection and control system (GCCS), which affects only the actual landfill. The
candlestick flare (item II.A.3) and the two generators that power the gas blower system
(item II.A.4), were observed operating on-site. Additional equipment such as: a 25Kw
generator for ground water pump, a 35Kw generator for the office/scale house, and a
10,000-gallon diesel above ground storage tank is on site and in use. These units were
included in original NOI but were not carried forward in this Title V permit or current
AOs (the scale house generator is listed in current AO).

II.B Requirements and Limitations.

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

II.B.1 Condition on Permitted Source (Source-wide)

II.B.1.a Condition:
Visible emissions caused by fugitive dust shall not exceed 10% at the property boundary, and
20% onsite. This opacity shall not apply when the wind speed exceeds 25 miles per hour if
the permittee has implemented, and continues to implement, the most recently approved
fugitive dust control plan in R307- 309-6 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;
(e) Other contingency measure approved by the director.
[Origin: R307-309-5]. [R307-309-5]

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II.B.1.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, adherence to the most
recently approved fugitive dust control plan shall be maintained in order to
demonstrate that appropriate measures are being implemented to control fugitive
dust.
II.B.1.a.2 Recordkeeping:

Records of measures taken to control fugitive dust shall be maintained to
demonstrate adherence to the most recently approved fugitive dust control plan. If
wind speeds are measured to establish an exception from the above visible
emissions limits, records of those measurements shall be maintained. Records shall
be maintained as described in Provision I.S.1 of this permit.
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 most current fugitive dust control plan (FDCP), dated February
19, 2019, is implemented to control on-site fugitive dust.
II.B.1.b Condition:

Visible emissions shall be no greater than 20 percent opacity, unless otherwise specified in
this permit. [Origin: DAQE-AN157920002-25]. [R307-401-8]

II.B.1.b.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a
quarterly basis by an individual trained on the observation procedures of 40 CFR
60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to
the Director. If visible emissions other than steam are observed from an emission
unit, an opacity determination of that emission unit shall be performed by a
certified observer within 24 hours of the initial survey. The opacity determination
shall be performed in accordance with 40 CFR 60, Appendix A, Method 9, or other
EPA- approved testing method, as acceptable to the Director, for point sources, and
in accordance with 40 CFR 51, Appendix M, Method 203C for fugitive emission
sources.

II.B.1.b.2 Recordkeeping:
The permittee shall record the date of each visual opacity survey and keep a list of
the emission points checked during the visual opacity survey. The permittee shall
also keep a log of the following information for each observed visual emission:
date and time visual emissions observed, emission point location and description,
time and date of opacity test, and percent opacity. The records required by this
provision and all data required by 40 CFR 60, Appendix A, Method 9 and 40 CFR
51 Method 203C shall be maintained in accordance with Provision I.S.1 of this
permit.

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II.B.1.b.3 Reporting:

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

Status:

In compliance – Quarterly Visible Emission Observations (VEOs) are conducted (by
third party) of the on-site flare and the four on-site diesel generators. It is not required
to perform VEOs for the well and administration generators, however they are still
conducted. Reviews of records show VEOs are done as method nine readings.

II.B.1.c Condition:

(1) If the permittee is responsible for construction or maintenance of any existing road or
has right of way easement or possesses the right to use the same whose activities result in
fugitive dust from the road, the permittee shall minimize fugitive dust to the maximum
extent possible. If materials are deposited that may create fugitive dust on a public or
private paved road, the permittee shall clean the road promptly.

(2) Unpaved Roads. If the permittee is responsible for construction or maintenance of any
new or existing unpaved roads, the permittee shall prevent, to the maximum extent
possible, the deposit of material from the unpaved road onto any intersecting paved road
during construction or maintenance. If materials are deposited that may create fugitive dust
on a public or private paved road, the permittee shall clean the road promptly.
[Origin: R307-309]. [R307-309-9]Monitoring:
II.B.1.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.
II.B.1.c.2 Recordkeeping:

Records that demonstrate compliance with this condition and records required
by the most recently approved fugitive dust control plan shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

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

Status:

In compliance – Salt, crushed slag, and sand are not used for on-site roads. Only
water and mag chloride are applied to unpaved roads to control fugitive dust. Mag
chloride is applied to roads once or twice a year. The on-site water truck is also
used to control fugitive dust. The site is off a dirt road which services other entities.

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II.B.2 Conditions on MSW Landfill

II.B.2.a Condition:

The permittee shall comply with all applicable requirements in 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.
(a) An active collection system shall:

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

(2) Collect gas from each area, cell, or group of cells in the landfill in which the
initial solid waste has been placed for a period of 5 years or more if action; or 2
years or more if closed or at final grade.
(3) Collect gas at a sufficient extraction rate.

(4) Be designed to minimize off-site migration of subsurface gas.
[62.16714(b)(2)]
(b) Control the gas collected from within the landfill through the use of control devices
meeting the following requirements, except as provided in 40 CFR 60.24:
[62.16714 (c)]

(1) A non-enclosed flare designed and operated in accordance with the parameters
established in 40 CFR 60.18 except as noted in 40 CFR 62.16722(d)
(c) The collection and control system may be capped, removed, or decommissioned if the
following condition’s criteria are met:
(1) The landfill is a closed landfill as defined in 40 CFR 62.16730. A closure
report shall be submitted to the EPA Administrator as provided in 40 CFR
62.16724(f);
(2) The collection and control system has been in operation a minimum of 15
years or the permittee demonstrates that the gas collection and control system will
be unable to operate for 15 years due to declining gas flow.
(d) Following the procedures specified in 40 CFR 62.16718(b), the calculated NMOC
emission rate at the landfill is less than 34 megagrams per year on three successive test
dates. The test dates shall be no less than 90 days apart, and no more than 180 days apart.
The permittee of a MSW landfill with a gas collection and control system used to comply
with the provisions of 40 CFR 62.16714(b) or 40 CFR 62.16714(c) shall comply with the
provisions for the operational standards in 40 CFR 63.1958 (as well as the provisions in 40
CFR 63.1960 and 40 CFR 63.1961). [Origin: 40 CFR 60 Subpart OOO]. [40 CFR
62.16710, 40 CFR 62.16714, 40 CFR 62.16716]

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II.B.2.a.1 Monitoring:
(a) After the installation and startup of a collection and control system in compliance with
this condition, the permittee shall calculate the NMOC emission rate for purposes of
determining when the system can be capped, removed, or decommissioned as provided
in 40 CFR 62.16714(f), using the equation provide below: [40 CFR 62.16718(b)]
MNMOC = 1.89 x 10-3 QLFG CNMOC
Where:

MNMOC = Mass emission rate of NMOC, megagrams per
year QLFG = Flow rate of landfill gas, cubic meters per
minute CNMOC = NMOC concentration, parts per million by volume as hexane
(1) The flow rate of landfill gas, QLFG, shall be determined by measuring the
total landfill gas flow rate at the common header pipe that leads to the control
system using a gas flow measuring device calibrated according to the
provisions of section 10 of EPA Method 2E of 40 CFR 60 appendix A-1.
(2) The average NMOC concentration, CNMOC, shall be determined by
collecting and analyzing landfill gas sampled from the common header pipe
before the gas moving or condensate removal equipment using the procedures
in EPA Method 25 Method or EPA Method 25C (Method 18 also listed as
option in WWW) of appendix A-7 of 40 CFR part 60. The sample location on
the common header pipe must be before any condensate removal or other gas
refining units. The landfill permittee shall divide the NMOC concentration
from EPA Method 25 or EPA Method 25C of appendix A-7 of 40 CFR part 60
by six to convert from CNMOC as carbon to CNMOC as hexane.
(3) The permittee may use another method to determine landfill gas flow rate
and NMOC concentration if the method has been approved by the EPA
Administrator.
(i) Within 60 days after the date of calculating the NMOC emission rate for
purposes of determining when the system can be capped or removed, the
permittee shall submit the results according to 40 CFR 62.6724(j)(2).
(b) For the performance test required in 40 CFR 62.16714(c)(1), the net heating value of
the combusted landfill gas as determined in 40 CFR 60.18(f)(3) is calculated from the
concentration of methane in the landfill gas as measured by EPA Method 3C. A
minimum of three 30-minute EPA Method 3C samples are determined. The
measurement of other organic compounds, hydrogen, and carbon monoxide is not
applicable. EPA Method 3C may be used to determine the landfill gas molecular weight
for calculating the flare gas exit velocity under 40 CFR 60.18(f)(4).
(i) Within 60 days after the date of completing each performance test (as
defined in 40 CFR 60.8), the permittee shall submit the results of the
performance tests required by 40 CFR 62.16718(b) or (d), including any

15
associated fuel analyses, according to 62.16724(j)(1).
(c) The permittee shall follow the compliance provisions in 40 CFR 63.1960 (as well as 40
CFR 63.1958 and 40 CFR 63.1961) for an MSW landfill with a gas collection and
control system used to comply with the provisions of 40 CFR 62.16714(b) or 40 CFR
62.16714(c).
(d) The permittee shall follow the monitoring provisions in 40 CFR 63.1961 (as well as 40
CFR 63.1958 and 40 CFR 63.1960) for an MSW landfill with a gas collection and
control system used to comply with the provisions of 40 CFR 62.16714(b) or 40 CFR
62.16714(c).
II.B.2.a.2 Recordkeeping:
(a) Except as provided in 40 CFR 62.16724(d)(2), the permittee of a MSW landfill subject to
the provisions of this condition shall keep for at least 5 years up to date, readily
accessible, on site records of the design capacity report which triggered this condition,
the current amount of solid waste in place, and the year by year waste acceptance rate.
Offsite records may be maintained if they are retrievable within 4 hours. Either paper
copy or electronic formats are acceptable. [40 CFR 62.16726(a)]
(b) Except as provided in 40 CFR 62.16724(d)(2), the permittee of a gas-controlled landfill
shall keep up-to-date, readily accessible records for the life of the control system
equipment of the data listed in paragraphs (b)(1) of this recordkeeping section as
measured during the initial performance test or compliance determination. Records of
subsequent tests or monitoring shall be maintained for a minimum of 5 years. Records of
the control device vendor specifications shall be maintained until removal.

(1) Where the permittee subject to the provisions of this condition seeks to
demonstrate compliance with 40 CFR 62.1614(c) through use of a non-
enclosed flare, the flare type (i.e., steam-assisted, air-assisted, or non-
assisted), all visible emission readings, heat content determination, flow rate
or bypass flow rate measurements, and exit velocity determination made
during the performance test as specified in 40 CFR 60.18; and continuous
records of the flare pilot flame or flare flame monitoring and records of all
periods of operations during which the pilot flame or the flare flame is absent.
(c) Except as provided in 40 CFR 62.16724(d)(2), a permittee of a controlled landfill subject
to the provisions of this condition shall keep for 5 years up-to-date, readily accessible
continuous records of the equipment operating parameters specified to be monitored in
40 CFR 62.16722 as well as up-to-date, readily accessible records for periods of
operation during which the parameter boundaries established during the most recent
performance test are exceeded.
(1) The permittee shall keep up-to-date, readily accessible continuous records
of the indication of flow to the control system and the indication of bypass
flow or records of monthly inspections of car-seals or lock-and-key
configurations used to seal bypass lines, specified under 40 CFR 62.16722.

16
(2) The permittee seeking to comply with the provisions of this condition by
use of a non- enclosed flare shall keep up-to-date, readily accessible
continuous records of the flame or flare pilot flame monitoring specified
under 40 CFR 62.16722(c), and up-to-date, readily accessible records of
all periods of operation in which the flame or flare pilot flame is absent.
(3) The permittee of a landfill seeking to comply with this condition using an
active collection system designed in accordance with 40 CFR 62.16714(b)
shall keep records of periods when the collection system or control device
is not operating.
(d) Except as provided in 40 CFR 62.16724(d)(2), the permittee shall keep for the life of the
collection system an up-to-date, readily accessible plot map showing each existing and
planned collector in the system and providing a unique identification location label for
each collector that matches the labeling on the plot map.
(1) The permittee shall keep up-to-date, readily accessible records of the
installation date and location of all newly installed collectors as specified
under 40 CFR 62.16720(b).
(2) The permittee shall keep readily accessible documentation of the nature,
date of deposition, amount, and location of asbestos-containing or non-
degradable waste excluded from collection as provided in 40 CFR
62.16728(a)(3)(i) as well as any nonproductive areas excluded from
collection as provided in 40 CFR 62.16728(a)(3)(ii).
(e) The permittee that chooses to comply with the provisions in 40 CFR 63.1958, 63.1960,
and 63.1961, as allowed in 40 CFR 62.16716, 62.16720, and 62.16722, must keep the
records in 40 CFR 62.16726(e)(6) and must keep records according to 40 CFR
63.1983(e)(1) through (5) in lieu of paragraphs (e)(1) through (5) of 40 CFR 60.16726(e).
(1) When complying with the provisions in 40 CFR 63.1958, 63.1960, and
63.1961 as allowed in 40 CFR 62.16716, 62.16720, and 62.16722, the
permittee shall keep records of the date upon which the permittee started
complying with the provisions in 40 CFR 63.1958, 63.1960, and 63.1961.
(f) Except as provided in 40 CFR 62.16724(d)(2), the permittee subject to the provisions of
this condition must keep for at least 5 years up-to-date, readily accessible records of all
collection and control system monitoring data for parameters measured in paragraph 40
CFR 62.16722(a)(1), (2), and (3).
(g) Any records required to be maintained by this subpart that are submitted electronically
via the EPA’s Central Data Exchange (CDX) may be maintained in electronic format.
(h) Records shall be maintained in accordance with Provision I.S.1. of this permit.

17
II.B.2.a.3 Reporting:
(a) The permittee who has already been required to submit a design plan under 40 CFR
62.16724(d), or under 40 CFR part 62, subpart GGG; 40 CFR part 60, subpart WWW; or
a state plan implementing subpart Cc of 40 CFR part 60, shall submit a revised design
plan to the EPA Administrator for approval as follows: [40 CFR 62.16724(e)]
(1) At least 90 days before expanding operations to an area not covered by the
previously approved design plan.
(2) Prior to installing or expanding the gas collection system in a way that is
not consistent with the design plan that was submitted to the EPA
Administrator according to 40 CFR 62.16724(d).
(b) The permittee of a controlled landfill shall submit a closure report to the EPA
Administrator within 30 days of ceasing waste acceptance. The EPA Administrator may
request additional information as may be necessary to verify that permanent closure has
taken place in accordance with the requirements of 40 CFR 258.60. If a closure report
has been submitted to the EPA Administrator, no additional wastes may be placed into
the landfill without filing a notification of modification as described under 40 CFR
60.7(a)(4).
(c) The permittee of a controlled landfill shall submit an equipment removal report to the
EPA Administrator 30 days prior to removal or cessation of operation of the control
equipment.
(1) The equipment removal report shall contain the following items:
(i) A copy of the closure report submitted in accordance with 40 CFR
62.16724(f);
(ii) A copy of the initial performance test report demonstrating that the 15-
year minimum control period has expired; unless the report of the results
of the performance test has been submitted to the EPA via the EPA's
CDX, or information that demonstrates that the gas collection and
control system will be unable to operate for 15 years due to declining
gas flows. In the equipment removal report, the process unit(s) tested,
the pollutant(s) tested, and the date that such performance test was
conducted may be submitted in lieu of the performance test report if the
report has been previously submitted to the EPA's CDX; and

(iii) Dated copies of three successive NMOC emission rate reports
demonstrating that the landfill is no longer producing 34 megagrams or
greater of NMOC per year, unless the NMOC emission rate reports have
been submitted to the EPA via the EPA's CDX. If the NMOC emission
rate reports have been previously submitted to the EPA's CDX, a
statement that the NMOC emission rate reports have been submitted
electronically and the dates that the reports were submitted to the EPA's
CDX may be submitted in the equipment removal report in lieu of the
NMOC emission rate reports; or

18
(2) The EPA Administrator may request such additional information as may
be necessary to verify that all of the conditions for removal in 40 CFR
62.16714(f) have been met.
(d) When complying with the operational provisions of 40 CFR 63.1958, 63.1960, and
63.1961, the permittee shall follow the semi-annual reporting requirements in 40 CFR
63.1981(h) in lieu of 40 CFR 62.16724(h)
(e) The permittee shall submit reports electronically according to 40 CFR 62.16724(j)(1) and
(2).
(f) When complying with the operational provisions of 40 CFR 63.1958, 63.1960, and
63.1961, the permittee shall follow the corrective action and the corresponding timeline
reporting requirements in 40 CFR 63.1981(j) in lieu of 40 CFR 62.16724(k)(1) and (2).
(g) When complying with the provisions in 40 CFR 63.1958, 63.1960, and 63.1961, the
permittee shall submit the 24-hour high temperature report according 40 CFR
63.1981(k).
(h) The permittee shall comply with the reporting requirements of the general provisions of
40 CFR 60 Subpart A, and 40 CFR 62 Subpart A as applicable.
(i) The permittee shall comply with the reporting requirements of Section I of this permit.
Status:

In compliance – All of the above, applicable regulations are conducted according to 40
CFR 62, Subpart OOO. See company reports.
Intermountain Regional Landfill (IRL) operates under Title V Operating Permit No.
4900334002, issued to IRL on December 20, 2023. Beginning in February 2023, IRL
began operating the Landfill Gas Collection System (LGCS) which includes 39
wellheads, two generators (one primary and a backup), two blowers (one primary
and a backup), and a candlestick flare. An additional nine wellheads (four East Bench
and five C-Lateral) were brought online in February 2024, and three more wellheads
(C-Lateral) in September 2024. Routine monitoring tasks required by 40 CFR § 62
Subpart OOO, 40 CFR § 63 Subpart AAAA were completed as required.
Based on Tier 2 Landfill Gas Testing dated July 2019 (prepared by Kleinfelder) and
submitted to the Utah DAQ in August 2019, the non-methane organic compound
(NMOC) emissions exceeded the 50 Mg/yr NMOC threshold. A LGCS design was
submitted to the Utah Department of Environmental Quality (DEQ) in August 2020,
and LGCS construction began in August 2021. The Approval Order (AO) for the
candlestick flare and associated generators was provided to IRL by Utah DAQ in
November 2022, followed by the Title V Operating Permit issued on December 20th,
2023.
Over the course of the reporting period in the first quarter of 2024, the facility has
incrementally increased the height of the top deck, multiple times in select locations.
Each lift on the top deck required wellheads to be raised prior to Municipal Solid
Waste (MSW) placement, subsequently leaving the wellheads inaccessible. Once
MSW was placed around the lifted wellheads, access could be regained.

19
Multiple wellhead locations suffered from missing data due to access safety issues
described above. As of March 2024, the top deck is up to grade with no additional lifts
planned.
IRL began recording collection system and control device startup, shutdown, and
malfunction events as required by 40 CFR § 63 Subpart AAAA beginning in March
of 2023, one month after initial startup.
The most recent report was submitted March 16, 2025, and covered the period from
October to December 2024. Reports have been submitted quarterly with semiannual
reports starting for calendar year 2025. Next report is due 30 days after June 30,
2025, end date.
Review of reports shows all required items are included and the reports are
completed.

II.B.2.b Condition:

The permittee shall comply with all applicable requirements in 40 CFR 63 Subpart AAAA –
National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills.
The permittee shall comply with the applicable General Provisions in 40 CFR 63,
Subpart A.
(a) Control System. The permittee shall route all the collected gas to a control system
that complies with the requirements below:
(1) A non-enclosed flare designed and operated in accordance with the parameters
established in 40 CFR 63.11(b) except as noted in 40 CFR 63.1959(e). [40 CFR
63.1959(b)(2)(iii)(A)]
(b) An active collection system shall:
(1) Be designed to meet the maximum expected gas flow rate from the entire area
of the landfill that warrants control over the intended use period of the gas
control system equipment;
(2) Collect gas from each area, cell, or group of cells in the landfill in which the
initial solid waste has been placed for a period of 5 years or more if active; or 2
years or more if closed or at final grade;
(3) Collect gas at a sufficient extraction rate;
(4) Be designed to minimize off-site migration of subsurface gas. [40 CFR
63.1959(b)(2)(ii)(B)]
(c) The collection and control system may be capped, removed, or decommissioned if
the following criteria are met: [40 CFR 63.1957(b)]
(1) The landfill is a closed landfill (as defined in 40 CFR 63.1990). A closure
report shall be submitted to the Director as provided in 40 CFR 63.1981(f);

20
(2) The gas collection and control system has been in operation a minimum of 15
years or the landfill permittee demonstrates that the gas collection and control
system will be unable to operate for 15 years due to declining gas flow; and
(3) Following the procedures specified in 40 CFR 63.1959(c), the calculated
NMOC emission rate at the landfill shall be less than 50 megagrams per year on
three successive test dates. The test dates shall be no less than 90 days apart,
and no more than 180 days apart.
(d) Operate the collection system such that gas is collected from each area, cell, or group
of cells in the MSW landfill in which solid waste has been in place for: [40 CFR
63.1958(a)]
(1) 5 years or more if active; or
(2) 2 years or more if closed or at final grade;
(e) Operate the collection system with negative pressure at each wellhead except under
the following conditions:
(1) A fire or increased well temperature. The permittee shall record instances when
positive pressure occurs in efforts to avoid a fire. These records shall be
submitted with the semi-annual reports as provided in 40 CFR 63.1981(h);
(2) Use of a geomembrane or synthetic cover. The permittee shall develop
acceptable pressure limits in the design plan;
(3) A decommissioned well. A well may experience a static positive pressure after
shut down to accommodate for declining flows. All design changes shall be
approved by the Director as specified in 40 CFR 63.1981(d)(2).
(f) Operate each interior wellhead in the collection system as specified in paragraph
(f)(1) or (f)(2) of this condition.
(1) Operate each interior wellhead in the collection system with a landfill gas
temperature less than 62.8 degrees Celsius (145 degrees Fahrenheit).
(2) The permittee may establish a higher operating temperature value at a particular
well. A higher operating value demonstration shall be submitted to the EPA
Administrator for approval and shall include supporting data demonstrating that
the elevated parameter neither causes fires nor significantly inhibits anaerobic
decomposition by killing methanogens. The demonstration shall satisfy both
criteria in order to be approved (i.e., neither causing fires nor killing
methanogens is acceptable).
(g) The permittee shall operate the collection system such that: [40 CFR 63.1958(d)]
(1) The methane concentration is less than 500 parts per million (ppm) above
background at the surface of the landfill. To determine if this level is exceeded,
the permittee shall conduct surface testing around the perimeter of the collection
area and along a pattern that traverses the landfill at 30-meter intervals and

21
where visual observations indicate elevated concentrations of landfill gas, such
as distressed vegetation and cracks or seeps in the cover. The permittee may
establish an alternative traversing pattern that ensures equivalent coverage. A
surface monitoring design plan shall be developed that includes a topographical
map with the monitoring route and the rationale for any site-specific deviations
from the 30-meter intervals. Areas with steep slopes or other dangerous areas
may be excluded from the surface testing.
(2) The permittee shall:
(i) Conduct surface testing using an organic vapor analyzer, flame
ionization detector, or other portable monitor meeting the specifications
provided in 40 CFR 63.1960(d).
(ii) Conduct surface testing at all cover penetrations. Thus, the permittee
shall monitor any cover penetrations that are within an area of the
landfill where waste has been placed and a gas collection system is
required.
(iii) Determine the latitude and longitude coordinates of each exceedance
using an instrument with an accuracy of at least 4 meters. The
coordinates shall be in decimal degrees with at least five decimal places.
(h) Operate the system in accordance with 40 CFR 63.1955(c) such that all collected
gases are vented to a control system designed and operated in compliance with 40
CFR 63.1959(b)(2)(iii). In the event the collection or control system is not operating:
(i) The gas mover system shall be shut down and all valves in the collection
and control system contributing to venting of the gas to the atmosphere
shall be closed within 1 hour of the collection or control system not
operating; and
(ii) Efforts to repair the collection or control system shall be initiated and
completed in a manner such that downtime is kept to a minimum, and
the collection and control system shall be returned to operation.
(i) Operate the control or treatment system at all times when the collected gas is routed
to the system.
(j) If monitoring demonstrates that the operational requirements in 40 CFR 63.1958(b),
(c), or (d) are not met, corrective action shall be taken as specified in 40 CFR
63.1960(a)(3) and (5) or (c). If corrective actions are taken as specified in 40 CFR
63.1960, the monitored exceedance is not a deviation of the operational requirements
in this condition.
(k) Operate the collection and control device in accordance with the provisions of 40
CFR 63.1958, 63.1960, and 63.1961. [40 CFR 63.1957(a)]
[Origin: 40 CFR 63 Subpart AAAA]. [40 CFR 63.1957(a) and (b), 40 CFR 63.1958(a)-(g),
40 CFR 63.1959(b)(2)(ii), 40 CFR 63.1964(b)]

22
II.B.2.b.1 Monitoring:

(a) After the installation and startup of a collection and control system in compliance
with 40 CFR 63 Subpart AAAA, the permittee shall calculate the NMOC emission
rate for purposes of determining when the system can be capped, removed, or
decommissioned as provided in paragraph 40 CFR 63.1957(b)(3), using equation 3.
[40 CFR 63.1959(c)]

(b) For the performance test required in 40 CFR 63.1959(b)(2)(iii)(A), the net heating
value of the combusted landfill gas as determined in 40 CFR 63.11(b)(6)(ii) is
calculated from the concentration of methane in the landfill gas as measured by EPA
Method 3C of 40 CFR 60 Appendix A. A minimum of three 30-minute EPA Method
3C samples are determined. The measurement of other organic components,
hydrogen, and carbon monoxide is not applicable. EPA Method 3C may be used to
determine the landfill gas molecular weight for calculating the flare gas exit velocity
under 63.11(b)(7) of subpart A.
(1) Within 60 days after the date of completing each performance test (as
defined in 63.7), the permittee shall submit the results of the performance
tests, including any associated fuel analyses, required by 40 CFR
63.1959(c) or (e) according to 40 CFR 63.1981(l)(1).
(c) The performance test required in 40 CFR 63.1959(b)(2)(iii)(A) shall be conducted
under such conditions as the Director specifies to the permittee based on
representative performance of the affected source for the period being tested.
Representative conditions exclude periods of startup and shutdown unless specified
by the Director. The permittee may not conduct performance tests during periods of
malfunction. The permittee shall record the process information that is necessary to
document operating conditions during the test and include in such record an
explanation to support that such conditions represent normal operation. Upon
request, the permittee shall make available to the Director such records as may be
necessary to determine the conditions of performance tests. [40 CFR 63.1959(f)]
(d) Except as provided in 40 CFR 63.1981(d)(2), the specified methods in paragraphs
(d)(1) through (d)(5) of this monitoring section shall be used to determine whether
the gas collection system is in compliance with 40 CFR 63.1959(b)(2)(ii). [40 CFR
63.1960(a)]
(1) For the purposes of calculating the maximum expected gas generation
flow rate from the landfill to determine compliance with 40 CFR
63.1959(b)(2)(ii)(C)(1), either equation (d)(1)(i) or (ii) of this monitoring
section shall be used. The permittee may use another method to determine
the maximum gas generation flow rate, if the method has been approved
by the EPA Administrator. The methane generation rate constant (k) and
methane generation potential (Lo) kinetic factors should be those
published in the most recent Compilation of Air Pollutant Emission
Factors (AP-42) or other site-specific values demonstrated to be
appropriate and approved by the Director. If k has been determined as
specified in 40 CFR 63.1959(a)(4), the value of k determined from the test
shall be used. A value of no more than 15 years shall be used for the
intended use period of the gas mover equipment. The active life of the

23
landfill is the age of the landfill plus the estimated number of years until
closure.
(i) For sites with unknown year-to-year solid waste acceptance rate:
Qm = 2Lo R (e-kc – e-kt)
Where:
Qm = Maximum expected gas generation flow rate, cubic meters per
year. Lo = Methane generation potential, cubic meters per megagram
solid waste.
R = Average annual acceptance rate, megagrams per year.
k = Methane generation rate constant, per year.
t = Age of the landfill at equipment installation plus the time the
permittee intends to use the gas mover equipment or active life of the
landfill, whichever is less. If the equipment is installed after closure, t is
the age of the landfill at installation, years.
c = Time since closure, years (for an active landfill c = O and e-kc = 1).
2 = Constant.
(ii) For sites with known year-to-year solid waste acceptance rate:
Qm = Sum (2 k Lo Mi (e-kti)) of i through n
Where:
Qm = Maximum expected gas generation flow rate, cubic meters per
year. k = Methane generation rate constant, per year.
Lo = Methane generation potential, cubic meters per megagram solid
waste.
Mi = Mass of solid waste in the ith section, megagrams.
ti = Age of the ith section, years.
(iii) If a collection and control system has been installed, actual flow data
may be used to project the maximum expected gas generation flow rate
instead of, or in conjunction with, the equations in paragraphs (d)(1)(i)
or (ii) of this monitoring section. If the landfill is still accepting waste,
the actual measured flow data will not equal the maximum expected
gas generation rate, so calculations using the equations in paragraphs
(d)(1)(i) or (ii) of this monitoring section, or other methods, shall be
used to predict the maximum expected gas generation rate over the
intended period of use of the gas control system equipment.
(2) For the purposes of determining sufficient density of gas collectors for
compliance with 40 CFR 63.1959(b)(2)(ii)(B)(2), the permittee shall
design a system of vertical wells, horizontal collectors, or other collection
devices, satisfactory to the Director, capable of controlling and extracting
gas from all portions of the landfill sufficient to meet all operational and

24
performance standards.
(3) For the purpose of demonstrating whether the gas collection system flow
rate is sufficient to determine compliance with 40 CFR
63.1959(b)(2)(ii)(B)(3), the permittee shall measure gauge pressure in the
gas collection header applied to each individual well, monthly. Any
attempted corrective measure shall not cause exceedances of other
operational or performance standards. An alternative timeline for
correcting the exceedance may be submitted to the EPA Administrator for
approval.
(i) If a positive pressure exists, follow the procedures as specified in 40
CFR 60.755(a)(3), except: If a positive pressure exists, action shall be
initiated to correct the exceedance within 5 days, except for the three
conditions allowed under 40 CFR 63.1958(b).
(A) If negative pressure cannot be achieved without excess air
infiltration within 15 days of the first measurement of positive
pressure, the permittee shall conduct a root cause analysis and
correct the exceedance as soon as practicable, but no later than 60
days after positive pressure was first measured. The permittee
shall keep records according to 40 CFR 63.1983(e)(3)
(B) If corrective actions cannot be fully implemented within 60 days
following the positive pressure measurement for which the root
cause analysis was required, the permittee shall also conduct a
corrective action analysis and develop an implementation
schedule to complete the corrective action(s) as soon as
practicable, but no more than 120 days following the positive
pressure measurement. The permittee shall submit the items listed
in 40 CFR 63.1981(h)(7) as part of the next semi-annual report.
The permittee shall keep records according to 40 CFR
63.1983(e)(4).
(C) If corrective action is expected to take longer than 120 days to
complete after the initial exceedance, the permittee shall submit
the root cause analysis, corrective action analysis, and
corresponding implementation timeline to the Director, according
to 40 CFR 63.1981(j). The permittee shall keep records according
to paragraph 40 CFR 63.1983(e)(5).
(4) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA
seeks to demonstrate compliance with the temperature and nitrogen or
oxygen operational standards in 40 CFR 63.1958(c) for the purpose of
identifying whether excess air infiltration into the landfill is occurring, the
permittee shall follow the procedures as specified in 40 CFR 60.755(a)(5),
except:
(i) Once the permittee subject to the provisions of 40 CFR 63 Subpart
AAAA seeks to demonstrate compliance with the operational standard
for temperature in 40 CFR 63.1958(c)(1), the permittee shall monitor

25
each well monthly for temperature for the purpose of identifying
whether excess air infiltration exists. If a well exceeds the operating
parameter for temperature as provided in paragraph 63.1958(c)(1),
action shall be initiated to correct the exceedance within 5 days. Any
attempted corrective measure shall not cause exceedances of other
operational or performance standards.
(A) If a landfill gas temperature less than or equal to 62.8 degrees
Celsius (145 degrees Fahrenheit) cannot be achieved within 15
days of the first measurement of landfill gas temperature greater
than 62.8 degrees Celsius (145 degrees Fahrenheit), the permittee
shall conduct a root cause analysis and correct the exceedance as
soon as practicable, but no later than 60 days after a landfill gas
temperature greater than 62.8 degrees Celsius (145 degrees
Fahrenheit) was first measured. The permittee shall keep records
according to 40 CFR 63.1983(e)(3).
(B) If corrective actions cannot be fully implemented within 60 days
following the temperature measurement for which the root cause
analysis was required, the permittee shall also conduct a corrective
action analysis and develop an implementation schedule to
complete the corrective action(s) as soon as practicable, but no
more than 120 days following the measurement of landfill gas
temperature greater than 62.8 degrees Celsius (145 degrees
Fahrenheit). The permittee shall submit the items listed in 40
CFR63.1981(h)(7) as part of the next semi-annual report. The
permittee shall keep records according paragraph 40 CFR
63.63.1983(e)(4).
(C) If corrective action is expected to take longer than 120 days to
complete after the initial exceedance, the permittee shall submit
the root cause analysis, corrective action analysis, and
corresponding implementation timeline to the Director, according
to paragraphs 40 CFR 63.1981(h)(7) and 63.1981(j). The
permittee shall keep records according to paragraph 40 CFR
63.1983(e)(5).

(D) If a landfill gas temperature measured at either the wellhead or at
any point in the well is greater than or equal to 76.7 degrees Celsius
(170 degrees Fahrenheit) and the carbon monoxide concentration
measured, according to the procedures in 40 CFR
63.1961(a)(5)(vi) is greater than or equal to 1,000 ppmv the
corrective action(s) for the wellhead temperature standard (62.8
degrees Celsius or 145 degrees Fahrenheit) must be completed
within 15 days.
(5) A permittee seeking to demonstrate compliance with 40 CFR
63.1959(b)(2)(ii)(B)(4) through the use of a collection system not
conforming to the specifications provided in 40 CFR 63.1962 shall
provide information satisfactory to the EPA Administrator as specified in
40 CFR 63.1981(d)(3) demonstrating that off-site migration is being

26
controlled.
(e) For purposes of compliance with 40 CFR 63.1958(a), the permittee of a controlled
landfill shall place each well or design component as specified in the approved
design plan as provided in 40 CFR 63.1981(d). Each well shall be installed no later
than 60 days after the date on which the initial solid waste has been in place for a
period of: [40 CFR 63.1960(b)]
(1) 5 years or more if active; or
(2) 2 years or more if closed or at final grade.
(f) The following procedures shall be used for compliance with the surface methane
operational standard as provided in paragraph 40 CFR 63.1958(d).
[40 CFR 63.1960(c)]
(1) After installation of the collection system, the permittee shall monitor
surface concentrations of methane along the entire perimeter of the
collection area and along a pattern that traverses the landfill at 30-meter
intervals (or a site-specific established spacing) for each collection area
on a quarterly basis using an organic vapor analyzer, flame ionization
detector, or other portable monitor meeting the specifications provided in
paragraph (d) of 40 CFR 60.1960
(2) The background concentration shall be determined by moving the probe
inlet upwind and downwind outside the boundary of the landfill at a
distance of at least 30 meters from the perimeter wells.
(3) Surface emission monitoring (SEM) shall be performed in accordance
with section 8.3.1 of Method 21 of 40 CFR 60 Appendix A-7, except that
the probe inlet shall be placed within 5 to 10 centimeters of the ground.
Monitoring shall be performed during typical meteorological conditions.
(4) Any reading of 500 parts per million or more above background at any
location shall be recorded as a monitored exceedance and the actions
specified in paragraphs (f)(4)(i) through (v) of this monitoring section
shall be taken. As long as the specified actions are taken, the exceedance
is not a violation of the operational requirements of 40 CFR 63.1958(d).
(i) The location of each monitored exceedance shall be marked and the
location and concentration recorded. The location shall be recorded
using an instrument with an accuracy of at least 4 meters. The
coordinates shall be in decimal degrees with at least five decimal places.
(ii) Cover maintenance or adjustments to the vacuum of the adjacent wells
to increase the gas collection in the vicinity of each exceedance shall be
made and the location shall be re-monitored within 10 days of detecting
the exceedance.

27

(iii) If the re-monitoring of the location shows a second exceedance,
additional corrective action shall be taken and the location shall be
monitored again within 10 days of the second exceedance. If the re-
monitoring shows a third exceedance for the same location, the action
specified in paragraph (f)(4)(v) of this monitoring section shall be taken,
and no further monitoring of that location is required until the action
specified in paragraph (f)(4)(v) of this monitoring section has been
taken.
(iv) Any location that initially showed an exceedance but has a methane
concentration less than 500 ppm methane above background at the 10-
day re-monitoring specified in paragraph (f)(4)(ii) or (iii) of this
monitoring section shall be re-monitored 1 month from the initial
exceedance. If the 1-month re-monitoring shows a concentration less
than 500 parts per million above background, no further monitoring of
that location is required until the next quarterly monitoring period. If the
1-month re-monitoring shows an exceedance, the actions specified in
paragraph (f)(4)(iii) or (v) of this monitoring section shall be taken.
(v) For any location where monitored methane concentration equals or
exceeds 500 parts per million above background three times within a
quarterly period, a new well or other collection device shall be installed
within 120 calendar days of the initial exceedance. An alternative
remedy to the exceedance, such as upgrading the blower, header pipes or
control device, and a corresponding timeline for installation may be
submitted to the EPA Administrator for approval.
(5) The permittee shall implement a program to monitor for cover integrity
and implement cover repairs as necessary on a monthly basis.
(g) A permittee seeking to comply with the provisions in 40 CFR 63.1960(c) shall
comply with the following instrumentation specifications and procedures for surface
emission monitoring devices: [40 CFR 63.1960(d)]
(1) The portable analyzer shall meet the instrument specifications provided in
section 6 of EPA Method 21 of 40 CFR 60 Appendix A, except that
"methane" shall replace all references to “VOC”.
(2) The calibration gas shall be methane, diluted to a nominal concentration
of 500 parts per million in air.
(3) To meet the performance evaluation requirements in section 8.1 of EPA
Method 21 of 40 CFR 60 appendix A, the instrument evaluation
procedures of section 8.1 of EPA Method 21 of 40 CFR 60 appendix A
shall be used

28
(4) The calibration procedures provided in sections 8 and 10 of EPA Method
21 of 40 CFR 60 appendix A shall be followed immediately before
commencing a surface monitoring survey.
(h) Once the permittee subject to the provisions of 40 CFR 63 Subpart AAAA seeks to
demonstrate compliance with the operational standard in 40 CFR 63.1958(e)(1), the
provisions of 40 CFR 63 Subpart AAAA apply at all times, including periods of
SSM. During periods of SSM, the permittee shall comply with the work practice
requirement specified in 40 CFR 63.1958(e) in lieu of the compliance provisions in
40 CFR 63.1960. [40 CFR 63.1960(e)(2)]
(i) A permittee seeking to comply with 40 CFR 63.1959(b)(2)(ii)(B) for an active gas
collection system shall install a sampling port and a thermometer, other temperature
measuring device, or an access port for temperature measurements at each wellhead
and: [40 CFR 63.1961(a)]
(1) Measure the gauge pressure in the gas collection header on a monthly basis
as provided in 40 CFR 63.1960(a)(3); and
(2) Monitor nitrogen or oxygen concentration in the landfill gas on a monthly
basis as follows:
(i) The nitrogen level must be determined using EPA Method 3C of 40
CFR 60 appendix A-2, unless an alternative test method is established as
allowed by 40 CFR 63.1981(d)(2).
(ii) Unless an alternative test method is established as allowed by 40 CFR
63.1981(d)(2), the oxygen level must be determined by an oxygen meter
using EPA Method 3A or 3C of 40 CFR 60 appendix A-2 or ASTM
D6522-11 (incorporated by reference, see 40 CFR 63.14). Determine the
oxygen level by an oxygen meter using EPA Method 3A or 3C of 40
CFR 60 appendix A-2 or ASTM D6522-11 (if sample location is prior to
combustion) except that:
(A) The span must be set between 10- and 12-percent oxygen;
(B) A data recorder is not required;
(C) Only two calibration gases are required, a zero and span;
(D) A calibration error check is not required; and
(E) The allowable sample bias, zero drift, and calibration drift are ±10
percent.
(iii) A portable gas composition analyzer may be used to monitor the oxygen
levels provided:
(A) The analyzer is calibrated; and

29
(B) The analyzer meets all quality assurance and quality control
requirements for EPA Method 3A of 40 CFR 60 appendix A-2 or
ASTM D6522-11 (incorporated by reference, see 40 CFR 63.14).
(3) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA
seeks to demonstrate compliance with the operational standard for
temperature in 40 CFR 63.1958(c), the permittee shall monitor the
temperature of the landfill gas on a monthly basis as provided in 40 CFR
63.1960(a)(4). The temperature measuring device shall be calibrated
annually using the procedure in Section 10.3 of EPA Method 2 of 40 CFR
60 appendix A-1.
(4) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA
seeks to demonstrate compliance with the operational standard for
temperature in 40 CFR 63.1958(c)(1), unless a higher operating
temperature value has been approved by the EPA Administrator under 40
CFR 63 Subpart AAAA or under 40 CFR 60, subpart WWW; 40 CFR 60,
subpart XXX; or a federal plan or EPA-approved and effective state plan
or tribal plan that implements either 40 CFR 60, subpart Cc or 40 CFR 60,
subpart Cf, the permittee shall initiate enhanced monitoring at each well
with a measurement of landfill gas temperature greater than 62.8 degrees
Celsius (145 degrees Fahrenheit) as follows:
(i) Visual observations for subsurface oxidation events (smoke, smoldering
ash, damage to well) within the radius of influence of the well.
(ii) Monitor oxygen concentration as provided in paragraph 40 CFR
63.1961(a)(2);
(iii) Monitor temperature of the landfill gas at the wellhead as provided in 40
CFR 63.1961(a)(4).
(iv) Monitor temperature of the landfill gas every 10 vertical feet of the well
as provided in 40 CFR 63.1961(a)(6).
(v) Monitor the methane concentration with a methane meter using EPA
Method 3C of 40 CFR 60 appendix A-6, EPA Method 18 of 40 CFR 60
appendix A-6, or a portable gas composition analyzer to monitor the
methane levels provided that the analyzer is calibrated and the analyzer
meets all quality assurance and quality control requirements for EPA
Method 3C or EPA Method 18.
(vi) Monitor and determine carbon monoxide concentrations, as follows:
(A) Collect the sample from the wellhead sampling port in a passivated
canister or multi-layer foil gas sampling bag (such as the Cali-5-
Bond Bag) and analyze that sample using EPA Method 10 of 40
CFR 60 appendix A-4, or an equivalent method with a detection
limit of at least 100 ppmv of carbon monoxide in high
concentrations of methane; or

30
(B) Collect and analyze the sample from the wellhead using EPA
Method 10 of 40 CFR 60 appendix A-4 to measure carbon
monoxide concentrations.
(C) When sampling directly from the wellhead, the permittee shall
sample for 5 minutes plus twice the response time of the analyzer.
These values must be recorded. The five 1-minute averages are
then averaged to give the permittee the carbon monoxide reading at
the wellhead.
(D) When collecting samples in a passivated canister or multi-layer foil
sampling bag, the permittee shall sample for the period of time
needed to assure that enough sample is collected to provide five (5)
consecutive, 1-minute samples during the analysis of the canister
or bag contents, but no less than 5 minutes plus twice the response
time of the analyzer. The five (5) consecutive, 1-minute averages
are then averaged together to give the permittee a carbon
monoxide value from the wellhead.
(vii) The enhanced monitoring in this paragraph (i)(4) shall begin 7 calendar
days after the first measurement of landfill gas temperature greater than
62.8 degrees Celsius (145 degrees Fahrenheit); and
(viii) The enhanced monitoring in this paragraph (i)(4) shall be conducted on
a weekly basis. If four consecutive weekly carbon monoxide readings
are under 100 ppmv, then enhanced monitoring may be decreased to
monthly. However, if carbon monoxide readings exceed 100 ppmv
again, the landfill shall return to weekly monitoring.
(ix) The enhanced monitoring in this paragraph (i)(4) can be stopped once a
higher operating value is approved, at which time the monitoring
provisions issued with the higher operating value should be followed, or
once the measurement of landfill gas temperature at the wellhead is less
than or equal to 62.8 degrees Celsius (145 degrees Fahrenheit).
(5) For each wellhead with a measurement of landfill gas temperature greater
than or equal to 73.9 degrees Celsius (165 degrees Fahrenheit), annually
monitor temperature of the landfill gas every 10 vertical feet of the well.
This temperature can be monitored either with a removable thermometer,
or using temporary or permanent thermocouples installed in the well.
(j) A permittee seeking to comply with 40 CFR 63.1959(b)(2)(iii) using a non-enclosed
flare shall install, calibrate, maintain, and operate according to the manufacturer’s
specification the following equipment: [40 CFR 63.1961(c)]
(1) A heat sensing device, such as an ultraviolet beam sensor or
thermocouple, at the pilot light or the flame itself to indicate the
continuous presence of a flame; and
(2) A device that records flow to the flare and bypass of the flare (if

31
applicable). The permittee shall:
(i) Install, calibrate, and maintain a gas flow rate measuring device that
shall record the flow to the control device at least every 15 minutes; and
(ii) Secure the bypass line valve in the closed position with a car-seal or a
lock-and-key type configuration. A visual inspection of the seal or
closure mechanism shall be performed at least once every month to
ensure that the valve is maintained in the closed position and that the gas
flow is not diverted through the bypass line.
(k) A permittee seeking to install a collection system that does not meet the
specifications in 40 CFR 63.1962 or seeking to monitor alternative parameters to
those required by 40 CFR 63.1958 through 40 CFR 63.1961 shall provide
information satisfactory to the EPA Administrator as provided in 40 CFR
63.1981(d)(2) and (3) describing the design and operation of the collection system,
the operating parameters that would indicate proper performance, and appropriate
monitoring procedures. The EPA Administrator may specify additional appropriate
monitoring procedures. [40 CFR 63.1961(e)]
(l) A permittee seeking to demonstrate compliance with the 500-ppm surface methane
operational standard in paragraph 40 CFR 63.1958(d) shall monitor surface
concentrations of methane according to the procedures 40 CFR 63.1960(c) and the
instrument specifications in 40 CFR 63.1960(d). If the permittee is complying with
the 500-ppm surface methane operational standard in paragraph 40 CFR
63.1958(d)(2), for location, the permittee shall determine the latitude and longitude
coordinates of each exceedance using an instrument with an accuracy of at least 4
meters and the coordinates shall be in decimal degrees with at least five decimal
places. In the semi-annual report in 40 CFR 63.1981(h), the permittee shall report
the location of each exceedance of the 500-ppm methane concentration as provided
in 40 CFR 63.1958(d). and the concentration recorded at each location for which an
exceedance was recorded in the previous month. Any closed landfill that has no
monitored exceedances of the operational standard in three consecutive quarterly
monitoring periods may skip to annual monitoring. Any methane reading of 500
ppm or more above background detected during the annual monitoring returns the
frequency for that landfill to quarterly monitoring.
(m) The monitoring requirements of 40 CFR 63.1961(a), (b), (c), (d), and (g) apply at all
times the affected source is operating, except for periods of monitoring system
malfunctions, repairs associated with monitoring system malfunctions, and required
monitoring system quality assurance or quality control activities. A monitoring
system malfunction is any sudden, infrequent, not reasonably preventable failure of
the monitoring system to provide valid data. Monitoring system failures that are
caused in part by poor maintenance or careless operation are not malfunctions. The
permittee is required to complete monitoring system repairs in response to
monitoring system malfunctions and to return the monitoring system to operation as
expeditiously as practicable. Where the permittee subject to the provisions of 40
CFR 63 Subpart AAAA seeks to demonstrate compliance with the temperature and
nitrogen or oxygen operational standards in introductory paragraphs 40 CFR
63.1958(c)(1), (d)(2), and (e)(1), the standards apply at all times.
[40 CFR 63.1961(h)]

32
II.B.2.b.2 Recordkeeping:
(a) Except as provided in 40 CFR 63.1981(d)(2), the permittee of a MSW landfill
subject to the provisions of 40 CFR 63.1959(b)(2)(ii) and (iii) shall keep for at least
5 years up to date, readily accessible, on site records of the design capacity report
which triggered 40 CFR 63.1959(b), the current amount of solid waste in place, and
the year by year waste acceptance rate. Off-site records may be maintained if they
are retrievable within 4 hours. Either paper copy or electronic formats are
acceptable. [40 CFR 63.1983(a)]
(b) Except as provided in 40 CFR 63.1981(d)(2), a permittee of a controlled landfill
shall keep up to date, readily accessible records for the life of the control equipment
of the data listed in paragraphs (b)(1) and (2) of this recordkeeping section as
measured during the initial performance test or compliance determination. Records
of subsequent tests or monitoring shall be maintained for a minimum of 5 years.
Records of the control device vendor specifications shall be maintained until
removal.
(1) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA
seeks to demonstrate compliance with 40 CFR 63.1959(b)(2)(ii):
(i) The maximum expected gas generation flow rate as calculated in 40
CFR 63.1960(a)(1).
(ii) The density of wells, horizontal collectors, surface collectors, or other
gas extraction devices determined using the procedures specified in 40
CFR 63.1962(a)(1) and (2).
(2) Where a permittee subject to this condition seeks to demonstrate
compliance with 40 CFR 63.1959(b)(2)(iii) through the use of a non-
enclosed flare, the flare type (i.e., steam- assisted, air-assisted, or non-
assisted), all visible emission readings, heat content determination, flow
rate or bypass flow rate measurements, and exit velocity determinations
made during the performance test as specified in 40 CFR 63.11;
continuous records of the flare pilot flame or flare flame monitoring and
records of all periods of operation during which the pilot flame or the
flare flame is absent.
(c) Except as provided in paragraph 40 CFR 63.1981(d)(2), a permittee of a controlled
landfill subject to the provisions of this condition shall keep for 5 years up to date,
readily accessible continuous records of the equipment operating parameters
specified to be monitored in 40 CFR 63.1961 as well as up to date, readily accessible
records for periods of operation during which the parameter boundaries established
during the most recent performance test are exceeded.
(1) The permittee shall keep up-to-date, readily accessible continuous records
of the indication of flow to the control system or the indication of bypass
flow or records of monthly inspections of car-seals or lock-and-key
configurations used to seal bypass lines, specified under 40 CFR
63.1961(b)(2)(ii), (c)(2)(ii), and (g)(2).

33
(2) The permittee seeking to comply with this condition by use of a non-
enclosed flare shall keep up-to-date, readily accessible continuous records
of the flame or flare pilot flame monitoring specified in 40 CFR
63.1961(c), and up-to-date, readily accessible records of all periods of
operation in which the flame or flare pilot flame is absent.
(3) A permittee seeking to comply with 40 CFR 63.1959(b)(2) using an active
collection system designed in accordance with 40 CFR 63.1959(b)(2)(ii)
shall keep records of periods when the collection system or control device
is not operating.
(4) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA
seeks to demonstrate compliance with the operational standard in
paragraph 40 CFR 63.1958(e)(1), the date, time, and duration of each
startup and/or shutdown period, recording the periods when the affected
source was subject to the standard applicable to startup and shutdown.
(5) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA
seeks to demonstrate compliance with the operational standard in 40 CFR
65.1958(e)(1), in the event that an affected unit fails to meet an applicable
standard, record the information below in this paragraph:
(i) For each failure, record the date, time and duration of each failure and
the cause of such events (including unknown cause, if applicable).
(ii) For each failure to meet an applicable standard; record and retain a list of
the affected sources or equipment.
(iii) Record actions taken to minimize emissions in accordance with the
general duty 40 CFR 63.1955(c), and any corrective actions taken to
return the affected unit to its normal or usual manner of operation.
(6) Beginning no later than September 27, 2021, in lieu of the requirements
specified in 40 CFR 63.8(d)(3) of subpart A, the permittee shall keep the
written procedures required by 40 CFR 63.8(d)(2) on record for the life of
the affected source or until the affected source is no longer subject to the
provisions of this part, to be made available for inspection, upon request,
by the Director. If the performance evaluation plan is revised, the
permittee shall keep previous (i.e., superseded) versions of the
performance evaluation plan on record to be made available for
inspection, upon request, by the Director, for a period of 5 years after
each revision to the plan. The program of corrective action should be
included in the plan required under 40 CFR 63.8(d)(2).
(d) Except as provided 40 CFR 63.1981(d)(2), the permittee shall keep for the life of the
collection system an up-to-date, readily accessible plot map showing each existing
and planned collector in the system and providing a unique identification location
label for each collector.

34
(1) The permittee shall keep up-to-date, readily accessible records of the
installation date and location of all newly installed collectors as specified
under 40 CFR 63.1960(b).
(2) The permittee shall keep readily accessible documentation of the nature,
date of deposition, amount, and location of asbestos containing or non-
degradable waste excluded from collection as provided in 40 CFR
63.1962(a)(3)(i) as well as any non- productive areas excluded from
collection as provided in 40 CFR 63.1962(a)(3)(ii).
(e) Except as provided in 40 CFR 63.1981(d)(2), the permittee shall keep for at least 5
years up- to-date, readily accessible records of the following: [40 CFR 63.1983(e)]
(1) All collection and control system exceedances of the operational standards
in 40 CFR 63.1958, the reading in the subsequent month whether or not
the second reading is an exceedance, and the location of each exceedance.
(2) A permittee subject to the control provisions of 40 CFR 63 Subpart
AAAA shall keep records of each wellhead temperature monitoring value
of greater than 55 degrees Celsius (131 degrees Fahrenheit), each
wellhead nitrogen level at or above 20 percent, and each wellhead oxygen
level at or above 5 percent, except:
(i) When a permittee subject to the provisions of 40 CFR 63 Subpart
AAAA seeks to demonstrate compliance with the compliance provisions
for wellhead temperature in40 CFR 63.1958(c)(1), the records of each
wellhead temperature monitoring value of 62.8 degrees Celsius (145
degrees Fahrenheit) or above instead of values greater than 55 degrees
Celsius (131 degrees Fahrenheit).
(ii) A permittee required to conduct the enhanced monitoring provisions in
40 CFR 63.1961(a)(5), shall also keep records of all enhanced
monitoring activities.
(iii) A permittee required to submit the 24-hour high temperature report in 40
CFR 63.1981(k), shall also keep a record of the email transmission.
(3) For any root cause analysis for which corrective actions are required in
paragraph 40 CFR 63.1960(a)(3)(i)(A) or (a)(4)(i)(A), keep a record of
the root cause analysis conducted, including a description of the
recommended corrective action(s) taken, and the date(s) the corrective
action(s) were completed.

35
(4) For any root cause analysis for which corrective actions are required in 40
CFR 63.1960(a)(3)(i)(B) or (a)(4)(i)(B), keep a record of the root cause
analysis conducted, the corrective action analysis, the date for corrective
action(s) already completed following the positive pressure reading or
high temperature reading, and, for action(s) not already completed, a
schedule for implementation, including proposed commencement and
completion dates.
(5) For any root cause analysis for which corrective actions are required in 40
CFR 63.1960(a)(3)(i)(C) or (a)(4)(i)(C), keep a record of the root cause
analysis conducted, the corrective action analysis, the date for corrective
action(s) already completed following the positive pressure reading or
high temperature reading, for action(s) not already completed, a schedule
for implementation, including proposed commencement and completion
dates, and a copy of any comments or final approval on the corrective
action analysis or schedule from the Director.
(f) Except as provided in 40 CFR 63.1981(d)(2), the permittee subject to the provisions
of 40 CFR 63 Subpart AAAA shall keep for at least 5 years up-to-date, readily
accessible records of all collection and control system monitoring data for
parameters measured in 40 CFR 63.1961(a)(1) through (6). [40 CFR 63.1983(g)]
(g) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA seeks to
demonstrate compliance with the operational standard for temperature in 40 CFR
63.1958(c)(1), the permittee shall keep the following records:
(1) Records of the landfill gas temperature on a monthly basis as monitored in
40 CFR 63.1960(A)(4).
(2) Records of enhanced monitoring data at each well with a measurement of
landfill gas temperature greater than 62.8 degrees Celsius (145 degrees
Fahrenheit) as gathered in 40 CFR 63.1961(a)(5) and (6).
(h) Any records required to be maintained by 40 CFR 63 Subpart AAAA that are
submitted electronically via the EPA's CEDRI may be maintained in electronic
format. This ability to maintain electronic copies does not affect the requirement for
facilities to make records, data, and reports available upon request to a delegated air
agency or the EPA as part of an on-site compliance evaluation. [40 CFR
63.1983(h)(2)(i)]
(i) Records shall be maintained in accordance with Provision I.S.1. of this permit.

II.B.2.b.3 Reporting:

Except as provided in paragraph 40 CFR 63.1981(d)(2):
(a) The permittee shall submit the reports specified in this Reporting section and the
reports specified in Table 1 to 40 CFR 63 Subpart AAAA. If the permittee
previously submitted a design capacity report, amended design capacity report,
initial NMOC emission rate report, initial or revised collection and control system
design plan, closure report, equipment removal report, or initial performance test

36
under 40 CFR part 60, subpart WWW; 40 CFR part 60, subpart XXX; or a federal
plan or EPA-approved and effective state plan or tribal plan that implements either
40 CFR part 60, subpart Cc or 40 CFR part 60, subpart Cf, then that submission
constitutes compliance with the design capacity report in 40 CFR 63.1981(a), the
amended design capacity report in 40 CFR 63.1981(b), the initial NMOC emission
rate report in 40 CFR 63.1981(c), the initial collection and control system design
plan in 40 CFR 63.1981(d), the revised design plan in 40 CFR 63.1981(e), the
closure report in 40 CFR 63.1981(f), the equipment removal report in 40 CFR
63.1981(g), and the initial performance test report in 40 CFR 63.1981(i). The
permittee does not need to re-submit the report(s). However, the permittee shall
include a statement certifying prior submission of the respective report(s) and the
date of submittal in the first semi-annual report required in this section.
[40 CFR 63.1981]
(b) Beginning no later than September 27, 2021, the permittee who has already been
required to submit a design plan under 40 CFR 63.1981(d) shall submit a revised
design plan to the Director for approval as follows: [40 CFR 63.1981(e)]
(1) At least 90 days before expanding operations to an area not covered by the
previously approved design plan.
(2) Prior to installing or expanding the gas collection system in a way that is
not consistent with the design plan that was submitted to the Director
according to 40 CFR 63.1981(d).
(c) A permittee of a controlled landfill shall submit a closure report to the Director
within 30 days of waste acceptance cessation. The Director may request additional
information as may be necessary to verify that permanent closure has taken place in
accordance with the requirements of 40 CFR 258.60. If a closure report has been
submitted to the Director, no additional wastes may be placed into the landfill
without filing a notification of modification as described under 40 CFR 63.9(b) of
subpart A. [40 CFR 63.1981(f)]
(d) A permittee of a controlled landfill shall submit an equipment removal report as
provided in 40 CFR 60.757(e). The permittee shall submit an equipment removal
report to the Director 30 days prior to removal or cessation of operation of the
control equipment. [40 CFR 63.1981(g)]
(1) The equipment removal report shall contain all of the following items:
(i) A copy of the closure report submitted in accordance with 40 CFR
63.1981(f);
(ii) A copy of the initial performance test report demonstrating that the 15-
year minimum control period has expired, or information that
demonstrates that the gas collection and control system will be unable to
operate for 15 years due to declining gas flows. In the equipment
removal report, the process unit(s) tested, the pollutant(s) tested, and the
date that such performance test was conducted may be submitted in lieu
of the performance test report if the report has been previously

37
submitted to the EPA's CDX; and
(iii) Dated copies of three successive NMOC emission rate reports
demonstrating that the landfill is no longer producing 50 Mg or greater
of NMOC per year. If the NMOC emission rate reports have been
previously submitted to the EPA's CDX, a statement that the NMOC
emission rate reports have been submitted electronically and the dates
that the reports were submitted to the EPA's CDX may be submitted in
the equipment removal report in lieu of the NMOC emission rate
reports.
(2) The Director may request such additional information as may be
necessary to verify that all of the conditions for removal in 40 CFR
63.1957(b) have been met.
(e) A permittee of a landfill seeking to comply with 40 CFR 63.1959(b)(2) using an
active collection system designed in accordance with 40 CFR 63.1959(b)(2)(ii) shall
submit to the Director semi-annual reports. The permittee shall submit the report,
following the procedure specified in 40 CFR 63.1981(l). For enclosed combustion
devices and flares, reportable exceedances are defined 40 CFR 63.1983(c). The
semi-annual reports shall contain the information in paragraphs (e)(1) through (8) of
this reporting section. [40 CFR 63.1981(h)]
(1) Number of times that applicable parameters monitored under 40 CFR
63.1958(b), (c), and (d) were exceeded and when the gas collection and
control system was not operating under 40 CFR 63.1958(e), including
periods of SSM. For each instance, report the date, time, and duration of
each exceedance.
(i) Where a permittee subject to the provisions of 40 CFR 63 Subpart
AAAA seeks to demonstrate compliance with the operational standard
for temperature in 40 CFR 63.1958(c), provide a statement of the
wellhead operational standard for temperature and oxygen the permittee
is complying with for the period covered by the report. Indicate the
number of times each of those parameters monitored under 40 CFR
63.1961(a)(3) were exceeded. For each instance, report the date, time,
and duration of each exceedance.
(2) Description and duration of all periods when the gas stream is diverted
from the control device or treatment system through a bypass line or the
indication of bypass flow as specified under 40 CFR 63.1961.
(3) Description and duration of all periods when the control device or
treatment system was not operating and length of time the control device
or treatment system was not operating.
(4) All periods when the collection system was not operating.
(5) The location of each exceedance of the 500 parts per million methane
concentration as provided in 40 CFR 63.1958(d), and the concentration
recorded at each location for which an exceedance was recorded in the

38
previous month. For location, the permittee shall record the latitude and
longitude coordinates of each exceedance using an instrument with an
accuracy of at least 4 meters. The coordinates shall be in decimal degrees
with at least five decimal places.
(6) The date of installation and the location of each well or collection system
expansion added pursuant to 40 CFR 63.1960(a)(3) and (4), (b), and
(c)(4).
(7) For any corrective action analysis for which corrective actions are
required in 40 CFR 63.1960(a)(3)(i) or (a)(5) and that take more than 60
days to correct the exceedance, the root cause analysis conducted,
including a description of the recommended corrective action(s), the date
for corrective action(s) already completed following the positive pressure
or high temperature reading, and, for action(s) not already completed, a
schedule for implementation, including proposed commencement and
completion dates.
(8) A permittee required to conduct enhanced monitoring in 40 CFR
63.1961(a)(5) and (6) shall include the results of all monitoring activities
conducted during the period.
(i) For each monitoring point, report the date, time, and well identifier along
with the value and units of measure for oxygen, temperature (wellhead
and downwell), methane, and carbon monoxide.
(ii) Include a summary trend analysis for each well subject to the enhanced
monitoring requirements to chart the weekly readings over time for
oxygen, wellhead temperature, methane, and weekly or monthly
readings over time, as applicable for carbon monoxide.
(iii) Include the date, time, staff person name, and description of findings for
each visual observation for subsurface oxidation event.
(f) The permittee shall submit information regarding corrective actions according to
paragraphs (f)(1) and (2) of this reporting section. [40 CFR 63.1981(j)]

(1) For corrective action that is required according to 40 CFR 63.1960(a)(3)
or (4) and is not completed within 60 days after the initial exceedance, the
permittee shall submit a notification to the Director as soon as practicable
but no later than 75 days after the first measurement of positive pressure
or temperature exceedance.
(2) For corrective action that is required according to 40 CFR 63.1960(a)(3)
or (4) and is expected to take longer than 120 days after the initial
exceedance to complete, the permittee shall submit the root cause
analysis, corrective action analysis, and corresponding implementation
timeline to the Director as soon as practicable but no later than 75 days
after the first measurement of positive pressure or temperature monitoring
value of 62.8 degrees Celsius (145 degrees Fahrenheit) or above, unless a

39
higher operating temperature value has been approved by the EPA
Administrator for the well under this subpart or under 40 CFR 60, subpart
WWW; 40 CFR part 60, subpart XXX; or a Federal plan or EPA
approved and effective state plan that implements either 40 CFR part 60,
subpart Cc or 40 CFR part 60, subpart Cf. The EPA Administrator must
approve the plan for corrective action and the corresponding timeline.
(g) Where a permittee subject to the provisions of 40 CFR 63 Subpart AAAA seeks to
demonstrate compliance with the operational standard for temperature in 40 CFR
63.1958(c)(1) and a landfill gas temperature measured at either the wellhead or at
any point in the well is greater than or equal to 76.7 degrees Celsius (170 degrees
Fahrenheit) and the carbon monoxide concentration measured is greater than or
equal to 1,000 ppmv, the permittee shall report the date, time, well identifier,
temperature and carbon monoxide reading via email to the Director within 24 hours
of the measurement unless a higher operating temperature value has been approved
by the EPA Administrator for the well under 40 CFR 63 Subpart AAAA or under 40
CFR part 60, subpart WWW; 40 CFR part 60, subpart XXX; or a Federal plan or
EPA approved and effective state plan or tribal plan that implements either 40 CFR
part 60, subpart Cc or 40 CFR part 60, subpart Cf. [40 CFR 63.1981(k)]
(h) The permittee shall submit reports electronically to the EPA according to 40 CFR
63.1981(l), (m), and (n).
(i) The permittee shall comply with the reporting requirements of the general provisions
of 40 CFR 63 as applicable.
(j) The permittee shall also comply with the reporting requirements of Section I of this
permit
Status: In compliance – All of the above, applicable regulations are conducted according to
40 CFR, 63 Subpart AAAA. See detailed status above.

II.B.2.c Condition:

The permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety
and good air pollution control practices for minimizing emissions. The general duty to
minimize emissions does not require the permittee to make any further efforts to reduce
emissions if the requirements of this subpart have been achieved. Determination of
whether a source is operating in compliance with operation and maintenance requirements
will be based on information available to the Director which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures, review of
operation and maintenance records, and inspection of the source. [40 CFR 63 Subpart
AAAA]. [40 CFR 63.1955(c)]

II.B.2.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

40
II.B.2.c.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and
maintenance. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

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

Status

In compliance – Maintenance is generally performed on-site. However, Cummins will
service on-site equipment on an as needed basis. Cummins provides maintenance
invoices. Maintenance records are kept on-site.

II.B.3 Conditions on Flare Station Generator Engines

II.B.3.a Condition:
Visible emissions shall be no greater than 20 percent opacity.
[Origin: DAQE-AN157920002-25]. [R307-401-8]
II.B.3.a.1 Monitoring:
A visual opacity survey of each affected emission unit shall be performed on a quarterly
basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, or other EPA-approved testing method, as acceptable to the Director. If visible
emissions other than steam are observed from an emission unit, an opacity determination
of that emission unit shall be performed by a certified observer within 24 hours of the
initial survey. The opacity determination shall be performed in accordance with 40 CFR
60, Appendix A, Method 9, or other EPA- approved testing method, as acceptable to the
Director, for point sources, and in accordance with 40 CFR 51, Appendix M, Method
203C for fugitive emission sources.

II.B.3.a.2 Recordkeeping:
The permittee shall record the date of each visual opacity survey and keep a list of the
emission points checked during the visual opacity survey. The permittee shall also keep a
log of the following information for each observed visual emission: date and time visual
emissions observed, emission point location and description, time and date of opacity test,
and percent opacity. The records required by this provision and all data required by 40
CFR 60, Appendix A, Method 9 and 40 CFR 51, Appendix M, Method 203C shall be
maintained in accordance with Provision I.S.1 of this permit.

41
II.B.3.a.3 Reporting:

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

Status: In compliance – See status of condition II.B.1.b.
II.B.3.b Condition:

The permitee shall not operate more than one 30 kW engine at one time.
[Origin: DAQE-AN157920002-25]. [R307-401-8]
II.B.3.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.b.2 Recordkeeping:
The permittee shall maintain daily records of operation, maintenance, and testing for each
engine. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.b.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of
this permit.
Status:

In compliance – The two 30 kW generator engines that power the landfill gas blower
system operate one at a time. The engines do not operate together. Telemetry allows the
engines to automatically operate on a rotating cycle.

II.B.3.c Condition:

The permittee shall only use diesel fuel (e.g. fuel oil#1, #2, or diesel fuel oil additives) as
fuel in the engines. The permittee of affected emission units with a displacement of less
than 30 liters per cylinder that use diesel fuel shall use diesel fuel that meets the following
ULSD per-gallon standard of 40 CFR 1090.305 for nonroad diesel fuel.
(1) Maximum sulfur content of 15 ppm and
(2) A minimum cetane index of 40 or a maximum aromatic content of 35
volume percent.
[Origin: 40 CFR 60 Subpart IIII, DAQE-AN157920002-25]. [40 CFR 60.4207, 40 CFR
63 Subpart ZZZZ, R307-401-8]

42
II.B.3.c.1 Monitoring:
Records required for this permit condition will serve as monitoring.
II.B.3.c.2 Recordkeeping:

The permittee shall maintain documentation that all diesel fuel meets the specification of 40
CFR 1090.305. Certification of diesel fuel shall be by fuel receipt records from the vendor
documenting test results. The diesel fuel purchase invoices and/or certification shall
indicate the diesel fuel meets the requirements in 40 CFR 1090.305. Records demonstrating
compliance with this condition shall be maintained in accordance with Provision I.S.1 of
this permit.
II.B.3.c.3 Reporting:

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

Status: In compliance – According to the Bridge Source invoices, only Ultra-Low Sulfur Diesel
(ULSD) was delivered to the landfill.

II.B.3.d Condition:
The permittee shall comply with the emission standards for new CI engines in 40 CFR
60.4201 for 2007 model year and later stationary CI ICE, as applicable. [40 CFR 60.4204(b)]
If the permittee conducts in-use performance tests on CI ICE, they shall meet the not-to
exceed (NTE) standards as indicated in 40 CFR 60.4212. [40 CFR 60.4204(d)]

Modified or reconstructed affected emission units shall meet the emission standards for
new nonroad CI ICE in 40 CFR 60.4204 (a) through (d) applicable to the model year,
maximum engine power, and displacement of the modified or reconstructed non-
emergency engine.
[40 CFR 60.4204(e)]

[Origin: 40 CFR 60.4204(b), 40 CFR 60.4204(d), 40 CFR 60.4204(e), DAQE-
AN157920001-22]. [40 CFR 60 Subpart IIII, R307-401-8]
II.B.3.d.1 Monitoring:
(a) The permitee shall comply by purchasing an engine certified to the emission standards in
40 CFR 60.4204(b) for the same model year and maximum engine power. The engine shall
be installed and configured according to the manufacturer’s emission-related
specifications, except as permitted below. [60.4211(c)]
(b) If the permittee does not install, configure, operate, and maintain affected emission units
and control devices according to the manufacturer’s emission-related written instruction,
or changes emission-related settings in a way that is not permitted by the manufacturer, the
permittee shall demonstrate compliance as follows, for affected emission units with
maximum engine power less than 100 HP:

43
(1) Keep a maintenance plan, daily records of conducted maintenance, daily
records of any testing performed; and
(2) To the extent practicable, maintain and operate the engine in a manner
consistent with good air pollution control practice for minimizing
emissions;
(3) Conduct an initial performance test to demonstrate compliance with the
applicable emission standards within 1 year after an engine and control
device is no longer installed, configured, operated, and maintained in
accordance with the manufacturer’s emission-related written instruction,
or within 1 year after changing emission-related settings in a way that is
not permitted by the manufacturer. [40 CFR 60.4211(g),
DAQE-AN157920001-22]
(c) For modified or reconstructed affected emission units that must comply with the standards
specified in 40 CFR 60.4204(e), the permittee shall demonstrate compliance by purchasing,
or otherwise owning or operating, an engine certified to the emission standards in 40 CFR
60.4204(e) or by conducting a performance test to demonstrate initial compliance with the
emission standards according to the requirements in 40 CFR 60.4212. The test shall be
conducted within 60 days after the engine commences operation after the modification or
reconstruction. [40 CFR 60.4211(e)].
(d) The permittee shall follow the applicable general provisions in Table 8 of 40 CFR 60
Subpart IIII. [40 CFR 60.4218(a)]
II.B.3.d.2 Recordkeeping:
Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.
II.B.3.d.3 Reporting:
There are no reporting requirements for this provision other than those specified in Section
I of this permit.
Status: In compliance – The two 30 kW (93.9) generator engines that power the landfill gas
blower system are Tier IV Certified Engines. All required maintenance is performed
and recorded. Units have non-resettable hour meters.
II.B.3.e Condition:
For all affected emission units, except those that are modified, reconstructed, or removed
from one existing location and reinstalled at a new location, the permittee shall comply with
paragraphs (a) through (b).
(a) After December 31, 2014, the permittee shall not install non-emergency stationary CI ICE
with a maximum engine power of greater than or equal to 19 KW (25 HP) and less than 56
KW (75 HP) that do not meet the applicable requirements for 2013 model year non-
emergency engines.

44
(b) In addition to the requirements specified in 40 CFR 60.4204, it is prohibited to import
stationary CI ICE with a displacement of less than 30 liters per cylinder that do not meet
the applicable requirements specified in paragraphs 40 CFR 60.4208 (a) through (g) after
the dates specified in 40 CFR 60.4208 (a) through (g).

[Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4208]

II.B.3.e.1 Monitoring:
Records required for this permit condition will serve as monitoring.
II.B.3.e.2 Recordkeeping:
The permittee shall keep records of the install date of each affected emission unit and
the applicable requirements under 40 CFR 60 Subpart IIII for the respective model year
engine. Records shall be maintained as described in Provision I.S.1 of this permit.
II.B.3.e.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In compliance – The two 30 kW (93.9 hp) generator engines, that power the landfill gas
blower system, were installed the first part of 2025, and appear to be operated according
to Subpart IIII. These are certified engines.
II.B.3.f Condition:
The permittee of stationary CI ICE shall operate and maintain stationary CI ICE that achieve
the emission standards as required in 40 CFR 60.4204 over the entire life of the engine.
[40 CFR 60.4206]
The permittee shall do all of the following, except as permitted in II.B.3.f.1(b):
(1) Operate and maintain the stationary CI internal combustion engine and
control device according to the manufacturer’s emission-related written
instructions
(2) Change only those emission-related settings that are permitted by the
manufacturer; and,
(3) Meet the requirements of 40 CFR part 1068, as they apply [40 CFR
60.4211(a)] [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4208,
40 CFR 60.4211(a)]
II.B.3.f.1 Monitoring:
(a) The permitee shall document activities performed to assure proper operation and
maintenance.

45
(b) If the permitee does not install, configure, operate, or maintain the engine and control
device according to the manufacturer’s emission-related written instruction, or the
permittee changes emission-related settings in a way that is not permitted by the
manufacturer, the permitee shall demonstrate compliance by:
(1) Keeping a maintenance plan and records of conducted maintenance; and
(2) To the extent practicable, maintain and operate the engine in a manner
consistent with good air pollution control practice for minimizing
emissions.
(3) In addition, if the permittee does not install and configure the engine and
control device according to the manufacturer's emission-related written
instructions, or the permittee changes the emission-related settings in a
way that is not permitted by the manufacturer, the permittee shall conduct
an initial performance test to demonstrate compliance with the applicable
emission standards within 1 year of such action. [40 CFR 60.4211(g)]
II.B.3.f.2 Recordkeeping:
Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.
II.B.3.f.3 Reporting:
There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In compliance – The 30 KW (93.9 hp) generator engines that power the landfill gas
blower system are operated and maintained as certified engines. Maintenance is
performed as required by subpart and manufactures guidelines per maintenance
tracking system.
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.
SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Title IV. This section is not applicable.

46
EMISSION INVENTORY: The 2023 tri-annual emission inventory was submitted on April
11, 2024.
Intermountain Regional Landfill’s 2023 Tri-Annual Emission
Inventory Summary:
Pollutants Total Tons/Year
PM10 14.867
PM2.5 3.02
SO2 0.60
NOx 19.34
VOC 6.30
CO 8.51
NH3 0.00

PREVIOUS
ENFORCEMENT ACTIONS:

Warning letter (DAQC-1223-22) was issued on September 14,
2022, for late ACC and 2020 Emission Inventory.

COMPLIANCE STATUS &
RECOMMENDATIONS: Source should be considered in compliance with the conditions
of Title V permit. Additional ice engines (as addressed above)
are in compliance with subpart as maintenance is done as
scheduled and ULS fuel is used.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE:

Discussed new AO required if previous engines used in future
as they were removed from AO and Permit. The additional
equipment was discussed with the company, the contractor, and
NSR section of DAQ. The units have been listed in past but are
not listed as part of Title V permit. NSR will determine if this
equipment will be listed in Title V permit or a separate AO will
be required.
RECOMMENDATION FOR
NEXT INSPECTION:

Contact Brian Alba to schedule the inspection. Inspect as usual.

ATTACHMENTS: VEO Form