Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
N2689
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-N2689-2014
VIENNA JUNCTION INDUSTRIAL PARK SANITARY LANDFILL
AND
VIENNA JUNCTION ENERGY, LLC
Located at
6233 and 6505 Hagman Road, Erie, Michigan 48133
SRN: N2689
Permit Number:
MI-ROP-N2689-2014
Staff Report Date:
April 21, 2014
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution
Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act
451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ),
Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions
of the Renewable Operating Permit (ROP).
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TABLE OF CONTENTS
APRIL 21, 2014 STAFF REPORT
3
MAY 22, 2014 STAFF REPORT ADDENDUM
9
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
N2689
APRIL 21, 2014 STAFF REPORT
ROP Number
MI-ROP-N2689-2014
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and
operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s
Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to
the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a
stationary source’s applicable requirements and compliance with them by consolidating all state and
federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the
draft permit terms and conditions including citations of the underlying applicable requirements, an
explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any
determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the
stationary source.
General Information
Stationary Source Mailing Address:
Source Registration Number (SRN):
North American Industry Classification System
(NAICS) Code:
Number of Stationary Source Sections:
Is Application for a Renewal or Initial Issuance?
Application Number:
Responsible Official – Section 1:
Responsible Official – Section 2:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively
Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
Vienna Junction Industrial Park Sanitary Landfill
6233 Hagman Road
Erie, Michigan 48133
and
Vienna Junction Energy, LLC
6505 Hagman Road
Erie, Michigan 48133
N2689
562212
2
Renewal
201300193
Mark O'Brien,
Area President, Allied Waste Systems of Michigan,
LLC
440-414-2301
Anthony J. Falbo,
Senior Vice President – Operations, Fortistar
716-439-1004
Glen Erickson, Senior EQA 12
517-780-7851
December 3, 2013
December 9, 2013
Yes
April 21, 2014
May 21, 2014
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Source Description
The Vienna Junction Industrial Park Sanitary Landfill (Vienna Junction LF) is a municipal solid waste
(MSW) landfill located in Erie, Michigan. The Vienna Junction LF (SECTION 1) is owned and operated by
Allied Waste Systems of Michigan, LLC. The total landfill footprint is approximately 145 acres. Vienna
Junction LF has design capacity greater than 2.5 million megagrams (Mg) and 2.5 million cubic meters
and has estimated uncontrolled emissions equal to or greater than 50 megagrams per year (Mg/yr) of
nonmethane organic compounds (NMOC). Final closure of the entire facility is projected in the year
2018. However, the actual closure date will depend on refuse acceptance rates and the degree of landfill
settlement. The landfill consists of several closed cells and areas that have not yet been constructed.
The landfill serves as the final disposal point for general and household waste and inert wastes such as
construction and demolition debris, foundry sand ash and low level contaminated soils. The facility also
accepts asbestos waste. The solid waste is transported to the facility to an area (cell) where it is
deposited on the working surface. The deposited waste is covered with soil or other MDEQ alternate
daily cover materials (ADCM) on a daily basis. When a cell reaches its design capacity, a liner is installed
covering the waste. Natural biological processes occurring in landfills decompose the waste producing
leachate and landfill gas. Initially, decomposition is aerobic until the oxygen supply is exhausted.
Anaerobic decomposition of buried refuse creates most of the landfill gas. Landfill gas consists mainly of
methane, carbon dioxide, and a small percentage of NMOC. The NMOC fraction consists of various
organic hazardous air pollutants (HAP), greenhouse gases, and volatile organic compounds (VOC).
At Vienna Junction LF the landfill gas (LFG) is collected through a series of vertical gas extraction
wells/horizontal collectors/connections to leachate sumps and cleanout risers. Collected gas is
transmitted to Vienna Junction Energy, LLC (VJE), formerly Gas Recovery Systems, LLC, (SECTION 2)
for treatment for off-site sale to an end user. During technical review a name and ownership change was
submitted. LFG intended to be sold is treated first by entering a fuel gas compressor. The LFG is
compressed to the pressure required to transmit the gas to the end user. The LFG temperature is raised
above the dew point by compression. The compressed LFG passes through an air-to-gas heat
exchanger and a gas-to-gas heat exchanger to condense water vapor. A chiller will operate intermittently
to further reduce the water vapor. Particulates and water are removed by a minimum of a 10 micron
coalescing filter. The LFG passes through a final gas-to-gas heat exchanger. The heat exchanger
reheats the LFG to approximately 20 degrees F above its dew point. This prevents any condensation of
the remaining water vapor in the LFG in the pipeline. The gas is then metered and enters the pipeline for
sale to the end user.
Any gas that is not conditioned by the treatment system and sold to an off-site customer is burned in the
enclosed flare owned by Vienna Junction LF. Both the treatment system and the enclosed flare are
subject to 40 CFR Part 60, Subpart A and WWW, because the equipment provides the air pollution
control of the NMOC emissions from the NSPS affected source.
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the 2012 submittal.
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TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
Nonmethane Organic Compounds (NMOC)
Tons per Year
18
NA
5
31.5
<1
<1
7
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs)
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
NA
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of
Greenhouse Gases in tons per year of CO2e is less than 100,000. CO2e is a calculation of the
combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are
subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the Non-Applicable Requirement part of the Staff
Report and identified in Part E of the ROP.
The stationary source is located in Monroe County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source, Vienna Junction LF, is a Type II sanitary landfill, which is a Municipal Solid Waste
(MSW) landfill. A Municipal Solid Waste landfill or a Type II landfill according to Act 451, Part 115, Solid
Waste Management is:
“A landfill which receives household waste, municipal solid waste incinerator ash or sewage
sludge and which is not a land application unit, surface impoundment, injection well, or waste pile.
A municipal solid waste landfill also may receive other types of solid waste, such as commercial
waste, non-hazardous sludge, conditionally exempt small quantity generator waste, and industrial
waste. Such a landfill may be publicly or privately owned.”
Natural biological processes occurring in landfills transform the waste’s constituents, producing leachate
and landfill gas. Initially, decomposition is aerobic until the oxygen supply is exhausted. Anaerobic
decomposition of buried refuse creates most of the landfill gas. Landfill gas (LFG) consists mainly of
methane, carbon dioxide, and NMOC. The NMOC fraction consists of various organic hazardous air
pollutants (HAP), greenhouse gases, and volatile organic compounds (VOC). LFG typically contains a
small percentage of non-methane organic compounds (NMOC), which was promulgated as a regulated
air pollutant under the Standards of Performance for New Stationary Sources, Subpart WWW –
Standards of Performance for Municipal Solid Waste Landfills (NSPS Subpart WWW).
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In Section 1, Vienna Junction LF has grouped their emission units in the following emission unit and
flexible groupings: EULANDFILL, EUACTIVECOLL, EUENCLOSEDFLARE, EUASBESTOS and
FGCOLDCLEANERS.
In Section 2, VJE has one emission unit in the grouping: EUTREATMENTSYS.
The Initial RO Permit contained Vienna Junction LF’s Permit to Install (PTI) No. 522-96 for an enclosed
flare, compressor internal combustion engine, and dehydration unit reboiler, referred to as “system” and
included emission limits, for the system as a group, for volatile organic compounds, nitrogen dioxide,
sulfur dioxide, and carbon monoxide. The flare was owned by Vienna Junction LF and VJE owned the
internal combustion engine (ICE) for gas compression and the dehydration unit reboiler. The “system”
emission limits were placed in both the EUENCLOSEDFLARE Table in Section 1 and the EUICENGINE
Table in Section 2. During the initial RO Permit technical review, it was determined that both the
compressor engine and reboiler were exempt from Rule 201.
In 2005 VJE dismantled and removed the dehydration boiler and ICE. An electric compressor is used
currently to compress the LFG as part of the EUTREATMENTSYS. The EUENCLOSEDFLARE was
modified/reconstructed in April, 2008 and is considered exempt from Rule 201 pursuant to Rule 285 (aa).
The performance test of the EUENCLOSEDFLARE was conducted in September 2008.
EULANDFILL, EUACTIVECOLL, EUTREATMENTSYS, and EUENCLOSEDFLARE are subject to Title
40 Code of Federal Regulations, Part 70 because the landfill is subject to the New Source Performance
Standard (NSPS) for Municipal Solid Waste Landfills, which was promulgated in Title 40 of the Code of
Federal Regulations, Part 60, Subparts A and WWW, and the Maximum Achievable Control Technology
(MACT) Standard for Municipal Solid Waste Landfills, which was promulgated in Title 40 of the Code of
Federal Regulations, Part 63, Subparts A and AAAA.
EULANDFILL, EUACTIVECOLL, EUTREATMENTSYS, and EUENCLOSEDFLARE are subject to the
NSPS for Municipal Solid Waste Landfills promulgated in Part 60 Subpart WWW the MACT for Municipal
Solid Waste Landfills promulgated in Part 63 Subpart AAAA, because Vienna Junction LF was modified
after 1991 and has a design capacity greater than 2.5 million megagrams (Mg) and 2.5 million cubic
meters (m3) and has estimated uncontrolled emissions equal to or greater than 50 megagrams per year
(Mg/yr) of non-methane organic compounds.
The stationary source is considered to be a minor source of HAP emissions because the potential to emit
of any single HAP regulated by the federal Clean Air Act, Section 112, is less than 10 tons per year and
the potential to emit of all HAPs combined are less than 25 tons per year.
EULANDFILL, EUACTIVECOLL, EUTREATMENTSYS, and EUENCLOSEDFLARE are not currently
subject to Prevention of Significant Deterioration (PSD) (40 CFR 52.21) regulations, because the
stationary source potential to emit of all criteria pollutants are less than 250 tons. However, future
modifications at this stationary source may be subject to PSD regulations.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all
applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring
Submittals."
The emission limitation(s) or standard(s) for VOC and NMOC from EULANDFILL, EUACTIVECOLL,
EUTREATMENTSYS, and EUENCLOSEDFLARE at the stationary source are exempt from the federal
Compliance Assurance Monitoring (CAM) regulation under Title 40 of the Code of Federal Regulations
(CFR), Part 64, because NMOC emissions from Municipal Solid Waste Landfills are addressed by 40
CFR, PART 60, NSPS Subpart WWW and 40 CFR, PART 63, Subpart AAAA (Landfill MACT).
Therefore, EULANDFILL, EUACTIVECOLL, EUTREATMENTSYS, and EUENCLOSEDFLARE are
exempt from CAM requirements for volatile organic compounds or NMOC.
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Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary
source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established
pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a
footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after
the effective date of ROP No. MI-ROP-N2689-2009 are identified in Appendix 6 of the ROP.
PTI Number
552-96
Streamlined/Subsumed Requirements
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and
213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the
AQD, if any were proposed in the application. These determinations are incorporated into the permit
shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to
Rule 213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under
Rule 212(4). These processes are not subject to any process-specific emission limits or standards in
any applicable requirement.
Exempt
Emission Unit ID
DV-LEACHATE
DV-FUEL TANKS
DV-FURNACES
DV-PROPANE
DVPOWERWASHER
DV-DIESEL TANK
Description of
Exempt Emission Unit
30,000 gallon leachate tank-Emergency
use only
(2) 200 gallon and (2) 550 gallon Diesel
Fuel Tanks – portable
Natural gas furnaces for comfort heat
500 gallon propane tank
Natural gas-hot water power washer
Rule 212(4)
Exemption
R 212(4)(f)
Rule 201
Exemption
R 285(aa)
R 212(4)(c)
R 284(d)
R 212(4)(b)
R 212(4)(c)
R 212(4)(b)
R 282(b)(i)
R 284(b)
R 282(b)(i)
10,000 gallon diesel fuel tank –
stationary
R 212(4)(c)
R 284(b)
Draft ROP Terms/Conditions Not Agreed to by Applicant
This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree
upon pursuant to Rule 214(2).
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Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable
requirements as of the effective date of this ROP.
Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public
and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit.
In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the
draft permit and related material. The AQD is not required to accept recommendations that are not
based on applicable requirements. The delegated decision maker for the AQD is Scott Miller, Jackson
District Supervisor. The final determination for ROP approval/disapproval will be based on the contents
of the permit application, a judgment that the stationary source will be able to comply with applicable
emission limits and other terms and conditions, and resolution of any objections by the USEPA.
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
ROP Number
N2689
MAY 22, 2014 STAFF REPORT ADDENDUM
MI-ROP-N2689-2014
Purpose
A Staff Report dated April 21, 2014, was developed in order to set forth the applicable requirements and
factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by
R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments
received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In
addition, this addendum describes any changes to the draft ROP resulting from these pertinent
comments.
General Information
Responsible Official – Section 1:
Responsible Official – Section 2:
AQD Contact:
Mark O'Brien,
Area President, Allied Waste Systems of Michigan,
LLC
440-414-2301
Anthony J. Falbo,
Senior Vice President – Operations, Fortistar
716-439-1004
Glen Erickson, Senior EQA 12
517-780-7851
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
Changes to the April 21, 2014 Draft ROP
No changes were made to the draft ROP.
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