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NORTH CAROLINA DIVISION OF

AIR QUALITY

Application Review

Issue Date: January X, 2018

Region: Washington Regional Office

County: Wayne

NC Facility ID: 9600269

Inspector’s Name: Peter Susi

Date of Last Inspection: 06/23/2017

Compliance Code: 3 / Compliance - inspection

Facility Data

Applicant (Facility’s Name): MP Wayne, LLC (Landfill Gas-to-Energy Project)

Facility Address:

MP Wayne, LLC (Landfill Gas-to-Energy Project)

460B South Landfill Road

Dudley, NC 28333

SIC: 4931 / Elec & Other Services Combined

NAICS: 221122 / Electric Power Distribution

Facility Classification: Before: Title V After: Title V

Fee Classification: Before: Title V After: Title V

Permit Applicability (this application only)

SIP: 02D .0516, .0521,

NSPS: 40 CFR Part 60 Subpart JJJJ

NESHAP: 40 CFR Part 63 Subpart ZZZZ

PSD: N/A

PSD Avoidance: Removed 02Q .0317 avoidance

of 02D .0530

NC Toxics: N/A

112(r): N/A

Other: NCGS §62-133.8 (g), SB3 BACT Analysis

Contact Data Application Data

Application Number: 9600269.17A,

9600269.17B

Date Received: 06/23/2017, 11/13/2017

Application Type: Renewal, Modification

Application Schedule: TV-Renewal, Significant

Modification

Existing Permit Data

Existing Permit Number: 10054/T04

Existing Permit Issue Date: 08/24/2015

Existing Permit Expiration Date: 02/28/2018

Facility Contact

Alex Zollinger

Site Operator

(919) 564-6007

460B South Landfill

Road

Dudley, NC 28333

Authorized Contact

Steve Laliberty

President

(860) 678-7537

One Grove Street, 6th

Floor

New Britain, CT 06053

Technical Contact

Steve Laliberty

President

(860) 678-7537

One Grove Street, 6th

Floor

New Britain, CT 06053

2016 0.9900 9.70 0.6700 50.80 3.00 10.66 9.89

[Formaldehyde]

2015 1.17 18.33 0.7900 67.20 3.49 0.9110 0.5571

[Hydrogen chloride (hydrochlori]

2014 1.43 20.60 0.9600 77.34 4.00 1.23 0.6776

[Hydrogen chloride (hydrochlori]

2013 1.41 21.22 0.9700 81.02 4.19 1.25 0.6870

[Hydrogen chloride (hydrochlori]

2012 1.22 18.66 0.8400 69.06 3.61 1.08 0.5990

[Hydrogen chloride (hydrochlori]

Review Engineer: Joshua L. Harris

Review Engineer’s Signature: Date:

Comments / Recommendations:

Issue: 10054/T05

Permit Issue Date: January X, 2018

Permit Expiration Date: December 31, 2022

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1. Purpose of Application

MP Wayne, LLC (Landfill Gas-to-Energy Project) [MP Wayne, LLC] applied for a renewal

(9600269.17A) of its Title V permit on June 23, 2017 – which is a little less than nine months prior to the

expiration date. Because the application was not received at least nine months in advance, the existing

permit may expire on February 28, 2018 unless the renewal permit has been issued on or before that date.

On November 13, 2017, another application (9600269.17A) for MP Wayne, LLC and the required

application fee were received in response to a letter the DAQ regional office sent to Mr. Steve Laliberty

on August 11, 2017 stating that MP Wayne, LLC must obtain a Title III air quality permit because its

formaldehyde emissions exceed the major source threshold of 10 tons per year. The second application

will be processed as a significant modification.

2. Facility Description

MP Wayne, LLC is the owner of a landfill gas-to-energy (LFGTE) facility located adjacent to the Wayne

County Municipal Solid Waste (MSW) Landfill on land owned by Wayne County. The LFGTE facility

operator is Wayne Landfill Electricity, LLC who leases the facility from MP Wayne.

Wayne Landfill Electricity, LLC operates the LFGTE facility and is only associated with the Wayne

County MSW Landfill in that it receives its landfill gas (LFG) for fuel and flares the excess LFG. The gas

is comprised of roughly a 50/50 mixture of methane and carbon dioxide that is created from decomposing

of MWS (garbage).1 Wayne County MSW Landfill extracts LFG through many wells and removes some

moisture, particulates and other impurities before providing this fuel to MP Wayne LLC. MP Wayne,

LLC uses this pre-treated/conditioned LFG to fuel three engine/electric power generators (gensets). The

energy produced with these gensets is sold the local power company (Duke Energy Progress). Duke

Energy Progress also purchases renewable energy certificates to help meet its regulatory renewable

energy obligation established in the North Carolina Renewable Energy Portfolio Standard. A flare serves

as a backup combustion device to burn the excess landfill gas.

Courtesy of Google Earth

1 The methane content of the LFG is typically 45 to 50 percent.

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The LFGTE facility is enclosed within a chain link fence on property that MP Wayne leases from Wayne

County and includes the following equipment:

• Gas treatment;

• Three GE Jenbacher model 320 LFG-fired, 4-stroke, lean burn, spark ignition reciprocating

internal combustion engines (RICE) (1468 horsepower- hp - output)/generators (1060 kilowatts –

kW - output) with a 36.9% electrical efficiency and a maximum 9,796 MBTU/hour (20,755 ft3/hr

gas firing rate - assuming fuel gas LHV is 472 MBTU/ft3). • An electrical transformer and associated equipment connecting the generator to the distribution

grid; and

• One LFG-fired open candlestick flare - ID No. ES-4; 1,600 standard cubic feet per minute (scfm)

maximum flow rate, 45.3 million Btu per hour heat input.

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The emission sources currently permitted include:

Emission

Source ID

Emission Source

Description

Control

System ID

Control System

Description

ES-EG1

[MACT, NSPS]

Landfill gas-fired engine (1468 hp output)/generator

(1060 kW generator output)

N/A N/A

ES-EG2

[MACT, NSPS]

Landfill gas-fired engine (1468 hp output)/generator

(1060 kW generator output) N/A N/A

ES-EG3

[MACT, NSPS]

Landfill gas-fired engine (1468 hp output)/generator

(1060 kW generator output) N/A N/A

ES-04 Landfill gas-fired open type backup flare (1,600 scfm

maximum flow rate)

N/A N/A

The LFGTE facility was placed into service in December 2010. The main operating scenario is the firing

of landfill gas in the three engine/generators (gensets). The three gensets would consume 545,000 mcf of

LFG per year if they were operated continuously at full load. The backup flare is only to be utilized when

one or more of the gensets is not in operation. The flare was not operated at all in 2016.

Data maintained by the U.S. Environmental Protection Agency (EPA) shows that as of March 2017, the

Wayne County Landfill had 2.4 million tons of MWS.2 EPA’s “LFG Energy Project Development

Handbook, estimates that each one million tons of MSW produces about 300 cubic feet per minute of

LFG for a 20 to 30 year period.3 For the Wayne County MSW landfill at this rate, the expected annual

LFG production would be around 378,000 thousand cubic feet (mcf) – which is consistent with the peak

LFG production in 2013.

Year LFG to Energy

(mcf) LFG Flared

(mcf) % of all LGF

Consumed as Fuel

2011 266,096 9695 96.4%

2012 323,350 5588 98.3%

2013 375,537 1847 99.5%

2014 372,243 532 99.9%

2015 305,739 300 99.9%

2016 258,365 0 100%

3. History/Background/Application Chronology:

• May 10, 2010 First-time state permit No. 10054R00 - allowed MP Wayne LLC to construct and

operate a LFGTE facility including the three LFG-fired engines.

• Oct. 27, 2010 State permit modification No. 10054R01- added a landfill gas-fired backup open

type flare.

• Mar. 28, 2013 First-time Title V Permit No. 10054T02 was issued to MP Wayne LLC with SB3

BACT limits added for the three LFG-fired engines.

• Oct. 15, 2013 Permit No. 10054T03 was issued as an administrative amendment to correct the

nitrogen oxides (NOx) emissions limit listed in the permit from Table 1 of 40 CFR

2 https://www.epa.gov/lmop/landfill-gas-energy-project-data-and-landfill-technical-data 3 LFG Energy Project Development Handbook, https://www.epa.gov/sites/production/files/2016-07/documents/pdh_chapter1.pdf

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60, Subpart JJJJ. Because the engines were manufactured in September 2009, the

correct NOx emissions limit is 3.0 g/hp-hour.

• Aug. 24, 2015 Permit No. 10054T04 was issued to change the name of the facility owner from

MP Wayne, LLC to MP Operations, LLC. The name of the facility stayed the

same.

• Jun. 23, 2017 Application 9600269.17A received for permit renewal.

• Aug. 11, 2017 Robert Fisher, Washington Regional Office (WaRO) Supervisor sent MP Wayne a

letter requesting that it submit a Title III permit application no later than September

30, 2017.

• Nov. 9, 2017 Title III Application 9600269.17B received.

4. Permit Modifications/Changes and TVEE Discussion:

The following sections were revised in the permit.

Pages Section Description of Changes

Throughout Throughout • Updated application/permit numbers.

• Updated dates.

3 1.0 Table • Consolidated the three engines and updated page numbers.

3 2.1 A Table • Removed PSD avoidance condition 15A NCAC 2Q.0317 of (2D

.0530)

3 to 5 2.1 A.1.b,

2.1 A.2.b,

2.1 B.1.b, and

2.1 B.2.d

• Added language stating if the results of a test exceed the permit limit,

the Permittee shall be deemed in noncompliance with applicable

standard.

4 2.1 B Table • Corrected the MACT reference.

5 2.1 B.2 • Revised the New Source Performance Standard (NSPS) testing

requirements

5 2.1 B.3 • Changed the condition to reflect the appropriate requirements for

engines located at a major source of hazardous air pollutants (HAPs)

6 2.1 B.4 • Reformatted and made other minor changes to the State Best Available

Control Technology requirements.

7 to 8 3.0 • Updated the General Conditions to Version 5.1.

No changes were made to the Title V Equipment Editor (TVEE) as no emissions sources or insignificant

activities were added, modified or removed with the permit renewal.

5. Regulatory Review:

This facility is subject to the following regulations, in addition to the requirements in the General

Conditions:

15A NCAC 02D .0516, Sulfur Dioxide Emissions from Combustion Sources

15A NCAC 02D .0521, Control of Visible Emissions

15A NCAC 02D .0524, New Source Performance Standards, 40 CFR 60, Subpart JJJJ

15A NCAC 02D .1111, 40 CFR 63, Subpart ZZZZ

15A NCAC 02D .0317, Avoidance of 02D .0530 (PSD)

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15A NCAC 02D .1100, Control of Toxic Air Pollutants

15A NCAC 02Q .0711, Emission Rates Requiring a Permit

NCGS §62-133.8 (g), SB3 BACT Analysis

02D .0516 “Sulfur Dioxide Emissions from Combustion Sources” Sulfur dioxide emissions from each

LFG-fired engine and the flare are limited to 2.3 pounds per million Btu heat input. LFG is considered

equivalent to natural gas and its combustion produces negligible sulfur dioxide emissions. No

monitoring, recordkeeping or reporting is required for LFG combustion. Compliance is indicated.

02D .0521 “Visible Emissions” All permitted sources at the facility are limited to 20% opacity. No

visible emissions have been observed from the engines during the site inspections or stack testing and

while it has not been observed in operation, no excessive visible emissions are expected from the open

flare. No monitoring, recordkeeping or reporting is required for LFG combustion. Compliance is

indicated.

02D .0535, “Notification Requirement” For excess emissions events lasting more than four hours that

result from a malfunction, a breakdown of process or control equipment or any other abnormal conditions

occur, the facility shall notify the Division of Air Quality by 9:00 a.m. and specify the facility name,

location, nature and cause of the excess emission, when it was first observed, its expected duration, and

the estimated amount emitted. No incidences of excess emissions lasting more than four hours have

occurred at the facility. Compliance is indicated.

State BACT Analysis [NC GS §62-133.8 (g)] – STATE ENFORCEABLE ONLY

North Carolina General Statute §62-133.7 (g) requires MP Wayne LLC to control the emissions of carbon

monoxide (CO), nitrogen oxides (NOx), volatile organic compounds (VOCs), particulate matter

(PM10/PM2.5), sulfur dioxide (SO2), mercury and lead from the three engines to the maximum extent that

has been determined to be achievable at the facility using Best Available Control Technology (BACT).

The following table lists BACT for each criteria pollutant and its maximum allowable emissions rate.

Annual stack tests have consistently shown compliance with the BACT emissions limit for CO and NOx.

MP Wayne has not been required to demonstrate compliance with the BACT limit for particulate matter

emissions.

Criteria

Pollutant

BACT for each engine BACT Limit

g/hp-hr

Stack Test Maximum g/hp-hr

Engine 1 Engine 2 Engine 3

CO Good combustion practices 3 2.9 2.3 3.0

NOx Good combustion practices 0.6 0.6 0.5 0.4

PM10/PM2.5 Good combustion practices 0.15 Not measured during test.

SO2 Good combustion practices and LFG fuel none Not measured during test.

VOC Good combustion practices and LFG fuel none Measured in ppmvd @ 15% O2

Lead Good combustion practices and LFG fuel none Not measured during test.

Mercury Good combustion practices and LFG fuel none Not measured during test.

MP Wayne burns only LFG in the engines and follows good combustion practices. Compliance is

expected.

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6. NSPS, NESHAP (MACT/GACT), PSD/NSR, RACT, Section 112(j), CAM:

New Source Performance Standards (NSPS), 15A NCAC 02D .0524, as promulgated in in 40 CFR 60

Subpart JJJJ, NSPS for Stationary Spark Ignition (SI) Internal Combustion Engines (ICE)

The three engines were manufactured in September 2009 and are subject to New Source Performance

Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines – specifically the standards

that apply to LFG-fired lean burn engines with a maximum engine power greater than or equal to 500 HP

and less than 1,350 HP and manufactured on or after January 2008. LFG-fired engines have no fuel

requirements but must be maintained and operated in a manner consistent with good air pollution control

practice for minimizing emissions. The engines must also meet the emission standards in §60.4233(e) for

an engine with a manufacture date of January 1, 2008.

The applicable NSPS emissions standards are as follows:

All three engines have been certified to these emission standards by the manufacturer for burning natural

gas but have not been certified to these emissions standards for burning LFG.

LFG contains small amounts of nitrogen, oxygen, carbon monoxide (CO), and nonmethane organic

compounds including volatile organic compounds (VOC). Some of the nitrogen content in the fuel is

oxidized to nitrogen oxides (NOx) and emitted along with other LFG constituents during the combustion

process. Additional NOx is formed from the high temperature oxidation of nitrogen present in the

Pollutant Emission Standard (must meet either one)

NOx 3.0 g/hp-hr 220 ppmvd at 15% O2

CO 5.0 g/hp-hr 610 ppmvd at 15% O2

VOC 1.0 g/hp-hr 80 ppmvd at 15% O2

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combustion air. Most CO emissions result from incomplete combustion of LFG. Good combustion

practices employed by MP Wayne LLC provide compliance with the emissions standards.

MP Wayne has conducted representative testing of one engine on an annual basis to show compliance for

all three engines. Stack testing performed at the MP Wayne LLC LFGTE facility has consistently

established compliance with the standards as shown in the table below:

*All stack reports have reviewed and accepted by the NCDAQ Stationary Source Compliance Branch.

Continued compliance is anticipated.

No other NSPS condition applies.

National Emissions Standards for Hazardous Air Pollutants (NESHAP), 15A NCAC 02D .1111

“Maximum Achievable Control Technology (MACT)” as promulgated in in 40 CFR 63

Subpart ZZZZ, NESHAP for Stationary Spark Ignition Reciprocating Internal Combustion

Engines

The three engines were manufactured in September 2009 and are subject to NESHAP requirements for

stationary Spark Ignition Reciprocating Internal Combustion Engines (SI RICE). Each was constructed

after December 2002, is more than 500 horsepower (HP) and burns exclusively landfill gas as fuel.

The existing NESHAP condition in the permit for the engines is based on the facility being an area source

of hazardous air pollutants (HAP) with a potential to emit of no more than 10 tons of any individual HAP

and no more than 25 tons of total HAP in any 12-month period. However, since the most recent non-

administrative permit revision, the North Carolina Division of Air Quality (NCDAQ) became aware of

performace test results that indicate significant levels of formaldehyde emissions for spark-ignited RICE

burning LFG. Formaldehyde is a Title III HAP. It is not present in LFG but is formed during the

combustion process. MP Wayne LLC not only has the potential to emit in excess of 10 tons of

formaldehyde in a 12-month period, its annual emissions of this HAP have been in excess of 10 tons.4

Therefore, the engines are subject to the 40 CFR 63 Subpart ZZZZ standards that apply to new LFG-fired

SI RICE with a site rating of more than 500 brake HP located at a major source of HAP instead of the

standards for an area source. These engines are required to meet the initial notification requirements of 40

CFR 63.6645(f) and must comply with the monitoring, recordkeeping and reporting requirements in 40

CFR 63.6625(c), 63.6650(g), and 63.6655(c). However, LFG-fired engines at major sources do not have

4 Based on the NCDAQ emission factor (1.107E-03 pounds /Hp-hour) for LFG-fired spark-ignition RICE, annual

formaldehyde emissions ranged from 11.0 to 12.5 tons during the 2012 to 2015 timeframe.

Test Date* Engine

Output kW

during Test

CO NOx VOC

ppm g/hp-hr ppm g/hp-hr ppm

8/11/2016 1 1051 332.4 2.86 35.6 0.503 10.9

6/18/2015 2 1060 265.2 2.28 34.2 0.483 11.8

6/25/2014 1 1000 394.3 2.93 54.5 0.646 4.6

6/19/2013 3 1000 389.1 Not Tested 34.5 0.443 13.7

6/19/2012 1 1059 308.4 Not Tested 53.9 Not Tested 0

6/19/2012 2 1059 295 Not Tested 48.1 Not Tested 0

NSPS Emissions Standard 610 5.0 220 80

Compliance with Standard? Yes Yes Yes

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to meet emissions or operational limits. Their applicable requirements include operating in a manner

which reasonably minimizes HAP emissions, monitoring and recording of daily fuel usage, maintaining

daily fuel usage monitor records, and annual reporting. Section 2.1.B.3 of the permit has been revised to

reflect the applicable NESHAP requirements for a major HAP source.

No other NESHAP condition applies.

Prevention of Significant Deterioration (PSD)/New Source Review (NSR), 15A NCAC 02D .0530

MP Wayne LLC is classified as minor source under PSD/NSR. When the flare was added, the facility

accepted a 250-ton per year limit on its CO emission to avoid triggering PSD/NSR review. Later, when a

CO BACT limit of 3.0 g/hp-hr for each engine was added to the permit in 2013 as required by N.C.G.S.

§62-133.8 (g), the maximum CO emissions from the three engines operating 8,760 hours per year

dropped to 125 tons per year. The flare emits less CO on a per MMBtu of LFG burned basis than the

engines and only operates when at least one of the engines is not online. Therefore, the facility is a minor

source of CO under PSD/NSR without the 250 ton per year limit. Potential emissions of all other criteria

pollutants are also less than the PSD/NSR major source threshold. Therefore, the 250 ton per year CO

limit has been removed from the permit – specifically from the table in Section 2.1.A with this renewal.

Reasonable Achievable Control Technology (RACT), 15A NCAC 02D .1400

RACT is required on existing sources in areas that are not meeting national ambient air quality standards

(i.e., non-attainment areas) and may be required in maintenance areas. The only area in North Carolina

subject to RACT is the Metrolina Ozone Maintenance Area. Because MP Wayne LLC is located outside

of the Metrolina area, it is not subject to any RACT requirements.

Section 112(r) of the Clean Air Act

MP Wayne LLC does not store any materials subject to Section 112® above the respective thresholds and

thus is not subject to the requirements under this Section.

Compliance Assurance Monitoring (CAM)

CAM applies to a control device if the following criteria are met:

1. The unit being controlled is subject to a non-exempt emission standard (as defined by 02D .0614(b)(1)),

2. The control device is being used to comply with the emission standard, and

3. The unit being controlled has potential emissions of the pollutant subject to the emission standard of

greater than major source thresholds.

Because no control devices are associated with the engines or the flare, CAM does not apply to MP

Wayne LLC.

7. Toxic Air Pollutants

MP Wayne triggered air toxics review when it added a LFG-fired backup open type (candlestick) flare

(ES-04). The flare was permitted after the July 10, 2010 – the date after which the toxic rule applies to

new combustion sources. Hydrochloric acid (HCl) was the only toxic air pollutant (TAP) associated with

the flare known to have potential facility emissions at a rate more than the toxic permit emission rate

(TPER). Compliance with the acceptable ambient level (AAL) was demonstrated with maximum facility-

wide HCl emissions at 0.26 pounds per hour modeled at 1 percent of the AAL.

The LFG-fired engines were exempt from air toxics at the time they were added to the permit but have

been shown to be a significant source of formaldehyde (an acute irritant TAP). When all engines operate

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simultanously at full capacity as much as 4.78 pounds per hour of formaldehyde may be emitted facility-

wide.56 The TPER for formaldehyde is 0.04 pounds per hour.

Matt Porter, Meteorologist with the NC Air Quality Analysis Branch, evaluated formaldehyde emissions

using air quality dispersion screening model to ensure the facility would pose no significant adverse

impact to public health. He modeled the emissions from one engine using AERSCREEN – the model

EPA finds, “produce(s) estimates of "worst-case" 1-hour concentrations for a single source, without the

need for hourly meteorological data.” After adjusting the AERSCREEN results to reflect the emissions

rate calculated based on the NCDAQ formaldehyde emission factor7, the maximum 1-hour formaldehyde

concentration was projected at 48.2 micrograms per cubic meter (µg/m3) at 50 meters from the stack and

22.4 µg/m3 at 100 meters from the stack. The AAL for formaldehyde is 150 µg/m3.

The facility wide worst-case impact should be no more than triple the ambient of the one engine.

Conservatively, the ambient concentration of formaldehyde should be less than the AAL at 50 meters and

less than half of the AAL at 100 meters from the source.8 South Landfill Road is about 50 meters from the

middle engine and nearest residence is located at least 200 meters east of the engines. Thus, the facility

operation should not significantly affect public health or warrant more refined toxics modeling.

Curtesy of Google Earth

8. Facility Emissions Review

For a historical review of emissions from this facility, see the summary table on the first page of this

review and the chart below. In the most recent emissions inventory report, MP Wayne reported that

during calendar year 2016, the facility emitted 50.8 tons of CO, 9.89 tons of formaldehyde (a toxic and

hazardous air pollutant); 9.7 tons of NOx, 3 tons of particulate matter (PM/PM10/PM2.5); 0.99 tons of

sulfur dioxide (SO2) and 0.67 tons of VOC. MP Wayne conservatively estimated CO and NOx emissions

at 2.94 g CO/hp-hr and 0.561 g NOx/hp-hr – rates that are more than the emissions measured in its 2016

stack test and more than the average of all stack tests. In previous years, even higher CO and NOx

emissions factors were used to calculate emissions.

5 In a letter to Steve Laliberty dated August 19, 2016, NCDAQ requested that MP Wayne use 0.001107 pounds of formaldehye

emitted per hp-hr as the emission factor for the annual emissions inventory unless it had approved site specific emissions data. 6 AP-42, Vol. I, Ch. 2.4: “Municipal Solid Waste Landfills”, Final Section, Nov. 1998 does not list formaldehyde as a constituent

of LFG and therefore, the flare is not expected to emit formaldehyde. 7 The NCDAQ emission factor is 1.107E-03 pounds of formaldehyde per Hp-hour output for LFG-fired spark-

ignition engines. 8 North Carolina has established the 1-hour AAL for formaldehyde, an acute irritant, at 150 µg/m3.

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9. Compliance Status

The facility was most recently inspected on June 23, 2017 by Peter Susi, NCDAQ Washington Regional

Office Environmental Specialist. Based on visual observations and records review, the facility appeared

to operate in compliance with all applicable air quality regulations and permit conditions at the time of

inspection.

Since MP Wayne, LLC began operations in 2010, it has received one notice of deficiency (NOD) and one

notice of violation (NOV). The NOD was issued in March 2012 for not demonstrating compliance with

the emission standards specified in §60.4233(d)/(e) per the requirements specified in §60.4244 and the

NOV was issued in March 2014 for failure to submit the annual compliance certification (ACC) by the

due date. Subsequently, MP Wayne, LLC performed stack testing and submitted its ACC to avoid

enforcement action.

10. Other Regulatory Concerns

Neither a PE seal or a zoning consistency form is required for this permit renewal or the significant Title

III modification.

11. Public Notice/EPA and Affected State(s) Review

A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521. The notice will

provide for a 30-day comment period, with an opportunity for a public hearing. Copies of the public

notice shall be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 02Q .0522, a

copy of each permit application, each proposed permit and each final permit pursuant shall be provided to

EPA.

Also, pursuant to 02Q .0522, a notice of the DRAFT Title V Permit shall be provided to each affected

State at or before the time notice is provided to the public under 02Q .0521 above.

The Public / EPA Notice periods began on X, 2017 and ended on X, 2017.

12. Recommendations

Issue permit 10054/T05

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

0

10

20

30

40

50

60

70

80

90

2010 2011 2012 2013 2014 2015 2016

LFG

Co

nsu

mp

tio

n (

mcf

)

Emis

sio

ns

(to

ns)

MP Wayne NOx and CO Emissions

Nox (tons) CO (tons) LFG (mcf)

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Attachment 1: Applicable NSPS and NESHAP Requirements

40 CFR 60 Subpart JJJJ—New Source Performance Standards for Stationary Spark Ignition (SI) Internal Combustion Engines (ICE)

§60.4233 What emission standards must I meet if I am an owner or operator of a

stationary SI internal combustion engine? (e) Owners and operators of stationary SI ICE with a maximum engine power greater than or equal to 75 KW (100

HP) (except gasoline and rich burn engines that use LPG) must comply with the emission standards in Table 1 to

this subpart for their stationary SI ICE. For owners and operators of stationary SI ICE with a maximum engine

power greater than or equal to 100 HP (except gasoline and rich burn engines that use LPG) manufactured prior to

January 1, 2011 that were certified to the certification emission standards in 40 CFR part 1048 applicable to engines

that are not severe duty engines, if such stationary SI ICE was certified to a carbon monoxide (CO) standard above

the standard in Table 1 to this subpart, then the owners and operators may meet the CO certification (not field

testing) standard for which the engine was certified.

§60.4243 What are my compliance requirements if I am an owner or operator of

a stationary SI internal combustion engine?

(b) If you are an owner or operator of a stationary SI internal combustion engine and must comply with the emission

standards specified in §60.4233(d) or (e), you must demonstrate compliance according to one of the methods

specified in paragraphs (b)(1) and (2) of this section.

(1) Purchasing an engine certified according to procedures specified in this subpart, for the same model year and

demonstrating compliance according to one of the methods specified in paragraph (a) of this section.

(2) Purchasing a non-certified engine and demonstrating compliance with the emission standards specified in

§60.4233(d) or (e) and according to the requirements specified in §60.4244, as applicable, and according to

paragraphs (b)(2)(i) and (ii) of this section.

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(ii) If you are an owner or operator of a stationary SI internal combustion engine greater than 500 HP, you must

keep a maintenance plan and records of conducted maintenance and must, to the extent practicable,

maintain and operate the engine in a manner consistent with good air pollution control practice for

minimizing emissions. In addition, you must conduct an initial performance test and conduct subsequent

performance testing every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate

compliance.

(a) If you are an owner or operator of a stationary SI internal combustion engine that is manufactured after July 1,

2008, and must comply with the emission standards specified in §60.4233(a) through (c), you must comply by

purchasing an engine certified to the emission standards in §60.4231(a) through (c), as applicable, for the same

engine class and maximum engine power. In addition, you must meet one of the requirements specified in (a)(1)

and (2) of this section.

(1) If you operate and maintain the certified stationary SI internal combustion engine and control device

according to the manufacturer's emission-related written instructions, you must keep records of conducted

maintenance to demonstrate compliance, but no performance testing is required if you are an owner or

operator. You must also meet the requirements as specified in 40 CFR part 1068, subparts A through D, as

they apply to you. If you adjust engine settings according to and consistent with the manufacturer's

instructions, your stationary SI internal combustion engine will not be considered out of compliance.

(2) If you do not operate and maintain the certified stationary SI internal combustion engine and control device

according to the manufacturer's emission-related written instructions, your engine will be considered a non-

certified engine, and you must demonstrate compliance according to (a)(2)(i) through (iii) of this section, as

appropriate.

(iii) If you are an owner or operator of a stationary SI internal combustion engine greater than 500 HP, you

must keep a maintenance plan and records of conducted maintenance and must, to the extent

practicable, maintain and operate the engine in a manner consistent with good air pollution control

practice for minimizing emissions. In addition, you must conduct an initial performance test within 1

year of engine startup and conduct subsequent performance testing every 8,760 hours or 3 years,

whichever comes first, thereafter to demonstrate compliance.

§60.4244 What test methods and other procedures must I use if I am an owner

or operator of a stationary SI internal combustion engine?

Owners and operators of stationary SI ICE who conduct performance tests must follow the procedures in paragraphs

(a) through (f) of this section.

(a) Each performance test must be conducted within 10 percent of 100 percent peak (or the highest achievable) load

and according to the requirements in §60.8 and under the specific conditions that are specified by Table 2 to this

subpart.

Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE)

§63.6590 What parts of my plant does this subpart cover?

(b) Stationary RICE subject to limited requirements. (1) An affected source which meets either of the criteria in

paragraphs (b)(1)(i) through (ii) of this section does not have to meet the requirements of this subpart and of subpart

A of this part except for the initial notification requirements of §63.6645(f).

(2) A new or reconstructed stationary RICE with a site rating of more than 500 brake HP located at a major source

of HAP emissions which combusts landfill or digester gas equivalent to 10 percent or more of the gross heat input

on an annual basis must meet the initial notification requirements of §63.6645(f) and the requirements of

P a g e | 14

§§63.6625(c), 63.6650(g), and 63.6655(c). These stationary RICE do not have to meet the emission limitations and

operating limitations of this subpart.

§63.6625 What are my monitoring, installation, collection, operation, and

maintenance requirements? (c) If you are operating a new or reconstructed stationary RICE which fires landfill gas or digester gas equivalent to

10 percent or more of the gross heat input on an annual basis, you must monitor and record your fuel usage daily

with separate fuel meters to measure the volumetric flow rate of each fuel. In addition, you must operate your

stationary RICE in a manner which reasonably minimizes HAP emissions.

§63.6655 What records must I keep? (c) If you are operating a new or reconstructed stationary RICE which fires landfill gas or digester gas equivalent to

10 percent or more of the gross heat input on an annual basis, you must keep the records of your daily fuel usage

monitors.

§ 63.6650 What reports must I submit and when? (g) If you are operating as a new or reconstructed stationary RICE which fires landfill gas or digester gas equivalent

to 10 percent or more of the gross heat input on an annual basis, you must submit an annual report according to

Table 7 of this subpart by the date specified unless the Administrator has approved a different schedule, according to

the information described in paragraphs (b)(1) through (b)(5) of this section. You must report the data specified in

(g)(1) through (g)(3) of this section.

(1) Fuel flow rate of each fuel and the heating values that were used in your calculations. You must also demonstrate

that the percentage of heat input provided by landfill gas or digester gas is equivalent to 10 percent or more of

the total fuel consumption on an annual basis.

(2) The operating limits provided in your federally enforceable permit, and any deviations from these limits.

(3) Any problems or errors suspected with the meters.