Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
N5986
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
ROP-MI-N5986-2015
REPUBLIC SERVICES OF MICHIGAN I, LLC – CARLETON FARMS LANDFILL
AND
SUMPTER ENERGY ASSOCIATES AT THE CARLETON FARMS LANDFILL
SRN: N5986
Located at
28800 Clark Road, New Boston, Michigan 48164
Permit Number:
ROP-MI-N5986-2015
Staff Report Date:
May 4, 2015
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).
Page: 1
TABLE OF CONTENTS
MAY 4, 2015 STAFF REPORT ................................................................................................................ 3
JUNE 5, 2015 STAFF REPORT ADDENDUM ......................................................................................... 9
Page: 2
Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
ROP Number
RENEWABLE OPERATING PERMIT
N5986
MAY 4, 2015 STAFF REPORT
ROP-MI-N5986-2015
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and
operate in compliance with an 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 Staff Report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for
the draft ROP terms and conditions including citations of the underlying applicable requirements, an
explanation of any equivalent requirements included in the draft ROP 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:
Carleton Farms Landfill
28800 Clark Road
New Boston, Michigan 48164
N5986
562212 – Solid Waste Landfill
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:
2
Renewal
201400066
Section 1:
Ralph Dach, General Manager
Republic Services of Michigan I, LLC
734-397-4523
AQD Contact:
Date Application Received:
Date Application Was Administratively Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
Section 2:
Dennis Plaster, Vice President of Operations
Sumpter Energy Associates, LLC
585-948-8580
Todd Zynda, Environmental Engineer
313-456-2761
Section 1: April 14, 2014
Section 2: January 14, 2014
April 14, 2014
Yes
May 4, 2015
June 3, 2015
Page: 3
Source Description
Carleton Farms Landfill is located in an area northwest of the intersection of Clark Road and OakvilleWaltz Road in Wayne County, just north of the border with Monroe County. The nearest residence is
directly east of the facility on Clark Road.
The Carleton Farms Landfill is owned and operated by Republic Waste Services of Michigan. The 664
acre landfill began accepting waste in 1993. The landfill has an overall design capacity of 103,965,200
cubic yards or 72,940,868 megagrams (Mg). The facillity accepted 797,350 Mg of waste during 2013. At
the conclusion of 2013, 19 percent of the overall landfill design capacity has been utilized.
The Carleton Farms Landfill is a Type II Sanitary Landfill, which currently accepts asbestos containing
wastes, industrial waste, industrial/construction demolition debris, miscellaneous solids, along with
municipal household waste. The solid waste is transported to the facility to an area (cell) where it is
deposited on the working surface. Solid waste arrives in a variety of vehicles that potentially generate
fugitive dust emissions. The deposited waste is covered with soil or other MDEQ approved alternate
daily cover materials (ADCM) on a daily basis. When a cell reaches its design capacity, a liner is
installed, covering the waste.
Municipal solid waste (MSW) initially undergoes aerobic microbial activity, which produces predominately
nitrogen gas and carbon dioxide. As oxygen levels decline, gas composition changes to a mixture of
methane and carbon dioxide. Landfill gas (LFG) typically contains a small percentage of non-methane
organic compounds (NMOC). The NMOC fraction consists of various organic hazardous air pollutants
(HAP), greenhouse gases, and volatile organic compounds (VOC). NMOC is the primary regulated air
pollutant associated with landfill gas generation, 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).
The landfill gas is collected at the Carleton Farms Landfill by a gas collection and control system. The
site has approximately 295 gas extraction wells. LFG is collected in horizontal and vertical wells and
routed to a header system via laterals from the wells. From the header system, the LFG is treated and
sent to Sumpter Energy Associates’ 14 internal combustion engines. The engines utilize the LFG from
the treatment system to generate electricity, which is sold to DTE Energy’s electrical power grid. An
enclosed flare and an open flare serve as backup control devices in the event of a malfunction of the
internal combustion engines. The requirements of these systems can be found in EULANDFILL,
EUACTIVECOLL, EUTREATMENTSYS, EUENCLOSEDFLARE, EUOPENFLARE, FGICENGINES1-8
and FGICENGINES9-14.
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System (MAERS) in the 2013 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
NMOC (surrogate for HAP per 40 CFR 63.1935)
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs)
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
Page: 4
Tons per Year
376
NA
105
29
19
1.12
25
Not Reported
Not Reported
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of
Greenhouse Gases (GHG) in tons per year of CO2e (carbon dioxide equivalents) is 380,350 tons. This
includes GHG emissions from both Republic Waste Services of Michigan and Sumpter Energy
Associates. CO2e is a calculation of the combined global warming potentials of six GHG (carbon dioxide,
methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the 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 Wayne County, which is currently designated by the United States
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants. A small
portion of Wayne County has been designated by the USEPA as nonattainment for sulfur dioxide (SO2).
Carleton Farms Landfill is not located within the SO2 nonattainment area.
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because
the potential to emit carbon monoxide and oxides of nitrogen exceed 100 tons. Additionally,
40 CFR §60.752(c) requires all landfills subject to 40 CFR Part 60 Subpart WWW, with capacities greater
than 2.5 million megagrams to apply for a Title V permit.
The stationary source is considered a major source of Hazardous Air Pollutant (HAP) emissions because
the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112 is greater than
10 tons per year and the potential to emit of all HAPs combined is greater than 25 tons per year.
EUICENGINE1 through EUICENGINE14 at the stationary source were subject to review under the
federal Prevention of Significant Deterioration regulations at 40 CFR 52.21 because at the time of New
Source Review permitting the potential to emit of carbon monoxide and nitrogen dioxide was greater than
250 tons per year.
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory
Greenhouse Gas Reporting Rule under 40 CFR Part 98 is not an ROP applicable requirement and is not
included in the ROP.
Although EUENCLOSEDFLARE was installed after August 15, 1967, this equipment was exempt from
New Source Review (NSR) permitting requirements at the time it was installed. However, future
modifications of this equipment may be subject to NSR.
EULANDFILL, EUACTIVECOLL, EUTREATMENTSYS, EUENCLOSEDFLARE, and EUOPENFLARE at
the stationary source are subject to the Standards of Performance for Municipal Solid Waste Landfills
promulgated in 40 CFR Part 60, Subparts A and WWW.
FGICENGINES1-8 and FGICENGINE9-14 are not subject to the Standards of Performance for Municipal
Solid Waste Landfills promulgated in 40 CFR Part 60, Subparts A and WWW. Landfill gas used in
FGICENGINES1-8 and FGICENGINE9-14 is treated in EUTREATMENTSYS prior to combustion.
EUTREATMENTSYS produces treated landfill gas that meets the requirements of
§60.572(b)(2)(B)(iii)(B). Therefore, 40 CFR Part 60, Subparts A and WWW are not applicable to
FGICENGINES1-8 and FGICENGINE9-14.
Page: 5
FGICENGINES1-8 and FGICENGINE9-14 at the stationary source are not subject to the Standards of
Performance for Stationary Spark Ignition Internal Combustion Engines promulgated in 40 CFR Part 60,
Subparts A and JJJJ as they were manufactured before July 1, 2007.
Leachate storage tanks (DVLEACHATE1, DVLEACHATE2 and DVLEACHATE3) are not subject to 40
CFR Part 60 Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels
[including Petroleum Liquid Storage Vessels] for Which Construction, Reconstruction, or Modification
Commenced After July 23, 1984). DVLEACHATE1 has a capacity of 500,000 gallons (1,873 cubic
meters [m3]). DVLEACHATE2 and DVLEACHATE3 both have a capacity of 80,000 gallons (300 m3).
The facility has demonstrated that leachate has a maximum true vapor pressure of less than 3.5
kilopascals (kPa). Subpart Kb (§60.110b(b)) states that “the subpart does not apply to storage vessels
with a capacity greater than or equal to 151 m3 storing a liquid with a maximum true vapor pressure less
than 3.5 kPA.” Therefore, Subpart Kb is not applicable.
EULANDFILL, EUACTIVECOLL, EUTREATMENTSYS, EUENCLOSEDFLARE, and EUOPENFLARE at
the stationary source are subject to the National Emission Standard for Hazardous Air Pollutants for
Municipal Solid Waste Landfills promulgated in 40 CFR Part 63, Subparts A and AAAA.
EUASBESTOS at the stationary source is subject to the National Emission Standard for Hazardous Air
Pollutants for Asbestos promulgated in 40 CFR Part 61, Subparts A and M.
EUICENGINE_3,
EUICENGINE_4,
EUICENGINE_7,
EUICENGINE_8,
EUICENGINE_9,
EUICENGINE_10, EUICENGINE_11, EUICENGINE_12, EUICENGINE_13 and EUICENGINE_14 at the
stationary source are subject to the National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines promulgated in 40 CFR Part 63, Subparts A and
ZZZZ (RICE Source MACT). The ROP contains special conditions for applicable requirements from 40
CFR Part 63, Subparts A and ZZZZ. The AQD is not delegated the regulatory authority for this area
source MACT.
EUICENGINE_1, EUICENGINE_2, EUICENGINE_5, EUICENGINE_6, at the stationary source are not
subject to the National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines promulgated in 40 CFR Part 63, Subparts A and ZZZZ (RICE Source
MACT) as the engines were constructed prior to December 19, 2002.
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 stationary source is not subject to the federal Compliance Assurance Monitoring (CAM) rule under
Title 40 of the Code of Federal Regulations, Part 64, because the emission limitation(s) or standard(s) for
municipal solid waste landfills are covered by 40 CFR Part 60 Subpart WWW and 40 CFR Part 63
Subpart AAAA. Therefore, Republic Services of Michigan and Sumpter Energy Associates are exempt
from CAM requirements.
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.
Page: 6
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after
the effective date of ROP No. MI-ROP-N5986-2009 are identified in Appendix 6 of the ROP.
C-10937 through C-10941
C-11553 through C-11555
62-01B
PTI Number
372-06
62-01
Streamlined/Subsumed Requirements
This ROP does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and
213(6).
Non-applicable Requirements
Part E of the ROP lists requirements that are not applicable to this source as determined by the AQD, if
any were proposed in the ROP Application. These determinations are incorporated into the permit shield
provision set forth in Part A (General Conditions 26 through 29) of the 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
DVDIESEL1
DVDIESEL1
DVDIESEL3
DVGASOLINE
DVLEACHATE1
DVLEACHATE2 and
DVLEACHATE3
DVUSEDOIL1
DVUSEDOIL2
DVMOTOROIL1
DVMOTOROIL2
DVHYDRAULIC
DVTRANSMISSION
Description of
Exempt Emission Unit
3,000 gallon mobile diesel
aboveground storage tank
8,000 gallon diesel aboveground
storage tank
500 gallon diesel fuel aboveground
storage tank
550 gallon gasoline aboveground
storage tank
500,000 gallon leachate
aboveground storage tank
Two 80,000 gallon leachate
aboveground storage tanks
550 gallon used oil aboveground
storage tank
1,000 gallon used oil aboveground
storage tank
1,000 gallon motor oil aboveground
storage tank
500 gallon motor oil aboveground
storage tank
500 gallon hydraulic oil aboveground
storage tank
550 gallon transmission oil
aboveground storage tank
Page: 7
Rule 212(4)
Exemption
R336.1212(3)(e)
Rule 201
Exemption
R336.1284(d)
R336.1212(3)(e)
R336.1284(d)
R336.1212(3)(e)
R336.1284(d)
R336.1212(4)(c)
R336.1284(g)(i)
R336.1212(3)(f)
R336.1285(aa)
R336.1212(3)(f)
R336.1285(aa)
R336.1212(3)(e)
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
Exempt
Emission Unit ID
DVGEAROIL
DVANTIFREEZE
DVGENERATOR
DVPROPANE1 and
DVPROPANE 2
DVPROPANE 3
through
DVPROPANE7
DVHEATERS
DVPORTABLES
DVPEROXIDE
DVNEWOIL
DVUSEDOIL
Description of
Exempt Emission Unit
275 gallon gear oil aboveground
storage tank
275 gallon antifreeze aboveground
storage tank
10,000 watt Dayton generator
Two 990 gallon aboveground
propane tanks
Five 500 gallon aboveground
propane tanks
Rule 212(4)
Exemption
R336.1212(3)(e)
Rule 201
Exemption
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
R336.1212(4)(b)
R336.1212(4)(c)
R336.1282(b)
R336.1284(b)
R336.1212(4)(c)
R336.1284(b)
Four propane fired space heaters
Five diesel fired portable welders,
generators, or pressure washers
6,000 gallon peroxide aboveground
storage tank
4,400 gallon aboveground new
engine lube oil tank
2,600 gallon aboveground used
engine lube oil tank
R336.1212(4)(b)
R336.1212(4)(b)
R336.1282(b)
R336.1282(b)
R336.1212(4)(c)
R336.1284(i)
R336.1212(3)(e)
R336.1284(c)
R336.1212(3)(e)
R336.1284(c)
Draft ROP Terms/Conditions Not Agreed to by Applicant
This draft ROP does not contain any terms and/or conditions that the AQD and the applicant did not
agree upon pursuant to Rule 214(2).
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 MDEQ, AQD
The AQD proposes to approve this ROP. 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 USEPA is allowed up to 45 days to review the draft ROP 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 Wilhemina McLemore, Detroit District Supervisor. The final
determination for ROP approval/disapproval will be based on the contents of the ROP 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.
Page: 8
Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
ROP Number
N5986
JUNE 5, 2015 STAFF REPORT ADDENDUM
ROP-MI-N5986-2015
Purpose
A Staff Report dated May 4, 2015, 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:
AQD Contact:
Section 1:
Ralph Dach, General Manager
Republic Services of Michigan I, LLC
734-397-4523
Section 2:
Dennis Plaster, Vice President of Operations
Sumpter Energy Associates, LLC
585-948-8580
Todd Zynda, Environmental Engineer
313-456-2761
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
Changes to the May 4, 2015 Draft ROP
No changes were made to the draft ROP.
The fifth paragraph on page 6 of the May 4, 2015 Staff Report is revised to read as follows.
“EUICENGINE_3,
EUICENGINE_4,
EUICENGINE_7,
EUICENGINE_8,
EUICENGINE_9,
EUICENGINE_10, EUICENGINE_11, EUICENGINE_12, EUICENGINE_13 and EUICENGINE_14 at the
stationary source are subject to the National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines promulgated in 40 CFR Part 63, Subparts A and
ZZZZ (RICE Source MACT). The ROP contains special conditions for applicable requirements from 40
CFR Part 63, Subparts A and ZZZZ.”
The language regarding the area source MACT was removed as the source is major of HAPs.
Page: 9