Draft/Proposed OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM July 18, 2019 TO: Phillip Fielder, P.E., Chief Engineer THROUGH: Rick Groshong, Senior Environmental Manager, Compliance and Enforcement THROUGH: Phil Martin, P.E., Engineering Manager, Existing Source Permits Section THROUGH: Ryan Buntyn, P.E., Existing Source Permits Section FROM: Mark Chen, P.E., New Source Permits Section SUBJECT: Evaluation of TV Construction Permit Application No. 2018-1814-C (M-1) Waste Management of Oklahoma, Inc. East Oak Recycling and Disposal Facility (Facility ID: 2061) 3201 Mosley Road, Oklahoma City, Oklahoma Latitude N 35.50749°, Longitude W 97.41459° Section 21, Township 12N, Range 2W Oklahoma City, Oklahoma County, Oklahoma Directions: From downtown OKC, take Interstate I-35 north for 3 miles, take NE 36th Street exit, go east on NE 36th Street for 2.5 miles, then, turn south into the facility. SECTION I. INTRODUCTION Waste Management of Oklahoma, Inc. (WM) has requested a Tier II construction permit for an operation at their East Oak Recycling and Disposal Facility (RDF) (SIC 4953, NAICS 562212). East Oak RDF is an active municipal solid waste (MSW) landfill under DEQ Land Protection Division (LPD) Solid Waste ID. No. 3555036. Currently, the facility is operating under Air Quality Division (AQD) Permit No. 2018-1814-TVR3, which was issued on June 10, 2019. The original landfill gas collection and control system (GCCS) and flare were constructed under Permit No. 96-471-C, which was issued on February 25, 1997. The original Title V Permit No. 99-405- TV was issued on January 31, 2001. In this construction permit application, WM plans to construct/install a Renewable Natural Gas (RNG) facility to treat/refine landfill gas (LFG) and to produce good quality gas (purity of methane > 97%) for injection into a natural gas pipeline at the site. This RNG facility will also be used to replace a gas-to-liquid (GTL) facility, which was operated by ENVIA Energy LLC since October 2016, but was found no longer operable in the fourth quarter of 2018. This GTL facility will be removed before the RNG facility can be constructed. The proposed RNG facility will have a thermal oxidizer to combust the waste gas and tail gas from the LFG processing operations and a backup process flare for emergency purpose, such as, process PERMIT MEMORANDUM No. 2018-1814-C (M-1) Draft/Proposed Page 2 upset conditions. The East Oak RDF also proposes to add an additional 350 SCFM utility flare to combust LFG from the closed Mosley Road portion of the landfill. WM also uses this opportunity to revise the SO2 emission estimation. The sulfur-containing compounds concentration in the LFG will be revised to a more conservative assumption of 500 ppmv from previous 200 ppmv in the Permit No. 2018-1814-TVR3. Upon applicant’s request, this permit will proceed through concurrent public and EPA review. AQD also uses this opportunity to update applicable state rules and federal regulations related to the facility. SECTION II. FACILITY DESCRIPTION The facility is comprised of two adjacent landfills, one is the Mosley Road Landfill and the other is East Oak RDF. The Mosley Road Landfill operated from 1975 to 1987, while the East Oak RDF began operations in 1987. A minor Title V modification in 2003 permitted the expansion of the East Oak RDF and allowed the site to fill in the area between the two original sites, thus creating one large landfill, which is known as East Oak RDF. The total land area is approximately 200 acres for landfill operation, and 50 acres are originally from Mosley Road Landfill and 150 acres are developed by East Oak RDF. Currently, the facility operates 6 days a week and receives nonhazardous solid waste from Great Metropolitan Oklahoma City Area, including Edmond, Yukon, Mustang, Moore and Norman. The facility typically receives approximately 2,000 ton/day of municipal, commercial, and industrial nonhazardous waste. The facility also accepts nonhazardous liquid and semi-solid waste at its solidification area. The East Oak RDF has increased their design capacity from approximately 18.413 million cubic yard (or 14.612 million Mg) to 19.808 million cubic yard (or 15.144 million Mg) in 2015. At the end of 2018, the facility is estimated to have accepted total waste of 11.488 million Mg, which is estimated based on WMO’s record and the EPA’s LandGEM Version 3.02 Model conducted on December 17, 2018. The remaining permitted capacity is approximately 3.656 million Mg. LFG is usually generated by microbiological processes associated with waste decomposition and LFG is composed primarily of methane (CH4) and carbon dioxide (CO2): CO2 content ranging from 30 to 50% and CH4 from 40 to 60%. Initial decomposition of the wastes is continuous and rapid until the entrained oxygen within the refuse is depleted. The second stage is anaerobic decomposition that can be divided into two separate and independent processes: non-methanogenic and methanogenic. CO2 is a byproduct of the non-methanogenic process and CH4 is a byproduct of the methanogenic process. LFG may contain small amounts of non-methane organic compounds (NMOC), which include trace volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). The production of LFG begins a few months after initial waste placement and continues until the microbial reactions are limited by substrate or moisture availability. LFG production is also affected by the solid waste disposal rate and varies over the life of the landfill. Generally, LFG production increases with time until a peak volume is reached shortly after landfill closure. In general, the LFG collection system consists of a network of vertical extraction wells, horizontal header pipes, and gas condensate sumps, and the collected LFG is processed and is either transported to off-site users or sent to an on-site flare. The RNG facility will be located at 3500 North Sooner Road on the same site as WM’s landfill operation (Section 21, Township 12N, Range 2W). The RNG facility will operate in a closed system with no atmospheric vents during normal operation. The LFG will first be treated by compression, dehydration, and filtration (which meets the definition of treatment for the NSPS) PERMIT MEMORANDUM No. 2018-1814-C (M-1) Draft/Proposed Page 3 after which it will pass through a gas processing system that removes water, carbon dioxide, volatile organic compounds (VOCs), sulfur compounds, oxygen, and other trace components from the LFG. The treated and processed methane is then compressed and delivered to the interstate pipeline. The waste gas stream from the processing system is routed to a thermal oxidizer for combustion. Because the facility has a landfill design capacity greater than 2.5 million Mg and 2.5 million cubic meters (m3) and has non-methane organic compound (NMOC) emission rate greater than 50 Mg/yr, the facility is required to comply with the New Source Performance Standards (NSPS) in Title 40 Code of Federal Regulations (CFR) Part 60, NSPS, Subpart WWW and 40 CFR Part 63, NESHAP, Subpart AAAA and is required to install and operate a gas collection and control system (GCCS). The facility has an active GCCS that routes collected landfill gas (LFG) from current approximate 125 extraction wells to the existing dual utility flares. The number of LFG extraction wells will be increased to comply with 40 CFR Part 60, NSPS Subpart WWW. Currently, the flare system is capable of processing 4,500 standard cubic feet per minute (SCFM) of LFG, which is limited by the capacity of the LFG blowers. SECTION III. EQUIPMENT Emission units (EU) have been arranged into Emission Unit Groups (EUG) in the Equipment Section. Table 1 lists the EUGs. Table 1. Emission Unit (EU) Information EU ID # Emission Sources EU Group Name EUG-1 Uncollectable LFG Fugitives & PM10 and PM2.5 Fugitives Landfill Operation From Earthmoving Operations EUG-2 Existing Dual Utility Flare System and New Utility Flare GCCS and LFG Flares EUG-3 Thermal Oxidizer and Process Flare RNG Processes There are three main sources of emissions at the facility. Once MSW is placed in the landfill, it is compacted and covered with soil/dirt/earth. The anaerobic decomposition of buried organic wastes within the covered landfill produces a biogas commonly referred to as LFG. EUG-1 includes uncollectable LFG fugitives and particulate matter emissions from fugitives, which is caused by earthmoving operation equipment, such as dozers, compactors, dump trucks, excavators, graders, and tractors. EUG-2 includes GCCS, existing LFG dual flare system (two 2,250 SCFM utility flares), and proposed 350 SCFM flare. The GCCS consists of a network of extraction wells (currently approximate 125 wells, with numbers changing over time) and collection pipes that collect LFG generated within the landfill. The GCCS is also comprised of a blower system which induces negative pressure within the landfill and transfers the collected LFG to the dual open flare system for burning or to the landfill gas treatment system that is part of the RNG processing facility. The East Oak RDF also proposes to add an additional 350 SCFM utility flare to combust LFG from the closed Mosley Road portion of the landfill. The GCCS is designed to operate continuously. EUG-3 includes all RNG processes and associated equipment. The treatment plant is part of RNG under this EUG. The RNG processes extract the methane (>97% purity in final product stream) from the LFG in a closed system with no atmospheric vents during normal operation. There are only two emission sources in RNG process, one is the thermal oxidizer (TO) and the other one is PERMIT MEMORANDUM No. 2018-1814-C (M-1) Draft/Proposed Page 4 the process flare.