November 10, 1987 Review of Air Emissions from a Landfill Site in Ventura County 23.26

23.26

10 NOV 1987
IN REPLY: A-3-1
REFER TO: NSA 2-5

Mr. Russ Baggerly
110 S. Poli Ave.
Meiners Oaks, Ca. 93023

Dear Mr. Baggerly,

Thank you for your may 28, 1984 inquiry to David P. Howekamp regarding environmental review of air emissions from a landfill site in Ventura County. The issues you raised in your letter regarding landfill emissions are not unique to Ventura Co. A landfill can be a significant source of emissions, and could be considered to be a stationary source.

A landfill would be subject to New Source Review (NSR), if its potential to emit, excluding fugitive emissions, exceeds the applicable major source cut-off. Fugitive emissions as defined in 40 CFR 51.18 (j)(1)(ix) are "those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening." The preamble to the 1980 NSR regulations characterizes nonfugitive emissions as "... those emissions which would ordinarily be collected and discharged through stacks or other functionally equivalent openings." Nationwide, landfills are not ordinarily constructed with gas collection systems. Therefore, emissions from existing or proposed landfills without gas collection systems are considered fugitive emissions and are not considered in federal NSR applicability determinations. We have discussed this issue with our headquarters Office and a copy of their response is attached for your information.

Landfill emissions that are collected would not qualify as fugitive emissions and could cause the landfill to be subject to NSR. If this is the case then it would be the actual pollutants emitted through the recovery system that would be subject to regulation. For example, if the gas is flared, the typical pollutants would be NOx and CO rather than VOCs.

District regulations may be more, but not less stringent that federal. In California, some local districts such as the Bay Area Air Quality Management District consider gas recovery systems to be the norm. In that district there are about twenty landfills that have been or are being permitted with gas collection systems. In the South Coast Air Quality Management District under its rule 1150.1, all new landfills must include a gas recovery system. Existing landfills must have collection systems by January 1, 1989.

As a point of clarification, 40 CFR 51.18 sets forth federal requirements for the State or District to develop a State Implementation Plan for stationary sources. Please note that in the case of the Weldon Canyon landfill, the applicable NSR regulations of the Ventura County Air Pollution Control District (APCD) would apply (not 40 CFR 51.18). Therefore, the APCD should be contacted to make this determination.

As you probably know, the emissions from this site should be included in the 1987 Air Quality Management Plan for Ventura County. The Plan is being drafted partly in response to the fact that Ventura County has been named as one of the four post 1987 non-attainment areas in California for ozone. It is the responsibility of the Ventura County APCD to consider all measures that would reduce emissions of pollutants that contribute to the post 87 non-attainment status. Certainly the ROC emissions from this facility, if they are of the magnitude stated in your letter, would exacerbate the ozone problem in Ventura. The District has, at its discretion, the power to propose emission controls, offsets, or other requirements beyond those required by current federal regulations, as part of its plan to achieve attainment of the National Ambient Air Quality Standards.

If you have further questions regarding this matter, please contact Janet Stromberg of the New Source Section at (415( 974-8218.

Sincerely,

[Original signed by Wayne Blackard]

Wayne A. Blackard, Chief New Source Section

Enclosure

cc: CAPB, Attn: Ray Menebroker Ventura County APCD, Attn: P. Baldwin

bc: OAQPS, Attn: Gary McCutchen
Notebook Entries: 24.12