Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
N6009
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-N6009-2012
Sauk Trail Hills Landfill, Inc.
SRN: N6009
Located at
5011 S. Lilley Road, Wayne, Canton, Michigan 48188
Permit Number:
MI-ROP-N6009-2012
Staff Report Date:
April 23, 2012
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 23, 2012 STAFF REPORT
3
JUNE 5, 2012, STAFF REPORT ADDENDUM
8
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
N6009
ROP Number
MI-ROP-N6009-2012
APRIL 23, 2012 STAFF REPORT
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:
Sauk Trail Development Landfill, Inc.
5011 S. Lilley Road
Canton, Michigan 48188
N6009
562212
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:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
1
Renewal
201100076
Ralph Dach, General Manager
734-397-4523
Erik A. Gurshaw, Environmental Quality Analyst
313-456-4704
June 20, 2011
June 20, 2011
Yes
April 23, 2012
May 23, 2012
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Source Description
Sauk Trail Hills (STH) Landfill is located just south of Michigan Avenue on Lilley Rd in the township of
Canton, County of Wayne. Light to medium industrial areas are located along the northern and eastern
property lines with some green space. The nearest residence is located approximately one-quarter mile
north of the facility. A Conrail easement runs along the south boundary of the site.
The landfill had 10.7 million tons of refuse in place through 2010 and will have 17.35 million tons in place
when closed.
The STH landfill is classified as a Type II sanitary landfill, which is a Municipal Solid Waste (MSW)
landfill. 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."
STH Landfill currently accepts sludge, asbestos containing wastes, fly ash, industrial waste,
miscellaneous solids, along with municipal household waste. Natural biological processes occurring in
landfills convert the waste into leachate and landfill gas. Initially, decomposition is aerobic until the
oxygen supply is exhausted. Anaerobic decomposition of buried refuse produces most of the landfill gas.
Landfill gas (LFG) consists mainly of methane, carbon dioxide, and non-methane organic compounds
(NMOC). NMOC is the primary regulated air pollutant associated with landfill gas generation, which was
promulgated as a regulated air pollutant under the New Source Performance Standard, Subpart WWW
for MSW landfills (NSPS Subpart WWW).
The LFG is collected at the STH Landfill by an active gas collection system. This system consists of
horizontal and vertical extraction wells that are installed into the landfill refuse to apply vacuum and
create a path for the migration of the LFG. The LFG migrates up through the wells and is combusted in
one of two open flares installed in 2012. The open flares replaced a previously existing enclosed flare
which was installed in 1998. A temporary open flare was installed in 2011 as an emergency
replacement when the existing enclosed flare failed. A performance test was performed on this
emergency open flare on September 28, 2011. Two new open flares were installed in 2012 to replace
the emergency open flare. The emergency open flare installed in 2011 was then removed.
Performance testing on the two open flares was conducted on February 14, 2012.
Other equipment present at the facility includes a 318,000-gallon leachate holding tank, a 720 gallon
used oil storage tank, two diesel fuel storage tanks each with 1,000 gallons capacity, four identical
heating furnaces rated at 80,400 BTU per hour, a 250 gallon used antifreeze storage tank, and three
500 gallon product oil storage tanks.
New Source Performance Standards (NSPS), Standards of Performance for MSW Landfills, codified at
40 CFR Part 60 Subpart WWW, are applicable to MSW landfills, which have a permitted capacity of
greater than 2.5 million megagrams (or 2.5 million cubic meters) and a construction, reconstruction or
modification date after May 30, 1991.
STH Landfill began accepting solid waste in 1975. In 1993, the facility received a new permit that
expanded the design capacity to greater than 2.5 million cubic meters. Consequently, STH is subject to
the standards of 40 CFR 60 Subpart WWW and the provisions of R336.1210.
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STH Landfill submitted an initial NMOC emission report to the Division on June 10, 1996. The facility
submitted a gas collection plan in March 1997. The gas collection and control system was installed and
became operational in 1998.
Canton Renewables (CR), LLC was issued Permit-To-Install (PTI) Number 98-11 for a high BTU landfill
gas compression and treatment facility as STH Landfill. CR, LLC is leasing a parcel of land from STH
Landfill to operate this facility. This facility will process LFG generated at STH Landfill and convert it into
pipeline quality natural gas. The processed natural gas will be sent to a natural gas pipeline in the area.
CR, LLC and STH Landfill have a contractual agreement in which STH Landfill provides LFG to CR’s,
LLC high BTU landfill gas processing facility. The contractual and spatial relationship between the two
facilities establishes STH Landfill as the controlling entity of the partnership. Therefore, the two facilities
are considered to be one stationary source under the definition of stationary source in Michigan Air
Pollution Rule 336.1119(r). Based on an agreement between the AQD, STH Landfill, and CR, LLC, the
two facilities will be issued two separate ROPs. CR, LLC applied for a modification to PTI Number 98-11
on January 13, 2012, for the addition of a 4200 scfm open flare which will be used to control gas
processed by the high BTU facility that does not meet federal pipeline gas specifications. Once PTI
Number 98-11 is modified, CR, LLC will apply for an initial ROP for the high BTU gas processing facility.
The following table lists stationary source emission information as reported to the Michigan Air
Emissions Reporting System (MAERS) in the 2010 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
Individual Hazardous Air Pollutants (HAPs) **
NMOC (surrogate for HAP per 40 CFR §63.19)
Total Hazardous Air Pollutants (HAPs)
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
Tons per Year
41
NA
24.6
30.2
2.4
14.5
35.1
35.1
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 tons. 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.
Wayne County is currently designated by the U.S. Environmental Protection Agency (USEPA) as a nonattainment area with respect to the PM 2.5 standard. Wayne County is currently designated as
attainment/unclassified for all other criteria pollutants.
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The stationary source is subject to 40 CFR Part 70 because 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. Landfills which have the potential to emit greater than 50 megagrams of NMOC per
year are required to install a gas collection and control system.
The stationary source is not currently subject to Prevention of Significant Deterioration (PSD) of Title 40
of the Code of Federal Regulations, §52.21, because its potential to emit of each criteria pollutant is less
than 100 tons per year. However, modifications at this stationary source may be subject to PSD
regulations.
The stationary source is subject to the New Source Performance Standards for MSW Landfills
promulgated in Title 40 of the Code of Federal Regulations, Part 60, Subparts A and WWW.
The stationary source is subject to the Maximum Achievable Control Technology Standards for MSW
landfills promulgated in Title 40 of the Code of Federal Regulations, Part 63, Subparts A and AAAA.
The stationary source is subject to the National Emission Standard for Hazardous Air Pollutants for
asbestos promulgated in Title 40 of the Code of Federal Regulations, Part 61, Subparts A and M.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all
applicable requirements and are consistent with the DEQ's "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 limitations or standards for
municipal solid waste landfills are covered by 40 CFR Part 60 Subpart WWW and 40 CFR Part 63
Subpart AAAA. Thus, STH Landfill, Inc. is 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. PTIs issued after the effective date of ROP
No. MI-ROP-N6009-2007 are identified in Appendix 6 of the ROP.
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).
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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
DVHEATER-BLDG
Description of
Exempt Emission Unit
Four identical heating furnaces rated
at 80,400 BTU per hour.
Rule 212(4)
Exemption
R 336.1212(4)(b)
Rule 201
Exemption
R 336.1282(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).
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 Wilhemina McLemore,
Detroit 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
N6009
JUNE 5, 2012, STAFF REPORT ADDENDUM
MI-ROP-N6009-2012
Purpose
A Staff Report dated April 23, 2012, 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:
Mr. Robert Dach, General Manager
734-397-4523
Mr. Erik Gurshaw, Environmental Quality Analyst
313-456-4704
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
Changes to the April 23, 2012, Draft ROP
No changes were made to the draft ROP.
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