Add-on Control Technologies Selective Non catalytic Reduction (SCNR) Selective Catalytic Reduction (SCR) Step 2: Eliminate technically infeasible options: The primary criterion for any emissions control technology that is being considered for controlling flare system emissions is that it should not impact the NMOC performance of the proposed flare system. Any modifications, that affect the combustion chemistry of the proposed flare system, will have adverse impacts on its NMOC performance. The proposed flare system combustion process is designed to maximize the NMOC destruction while optimizing the emissions of CO and NOx. The low-NOx burner option under the stoichiometry based combustion modifications category is already incorporated in the proposed flare system design as demonstrated by the low level of NOx (0.06 lb/MMbtu). The flue gas re circulation identified under the dilution based combustion modifications is not applicable to the proposed flare system because any circulation of high temperature gases back into combustion chamber is not expected to lower the NOx level. The water/steam injection identified under the dilution based combustion modifications is not applicable to the proposed flare system because any lowering of combustion zone temperature by adding water or steam will adversely affect NMOC performance. In addition, the use of steam will require a steam generating plant nearby resulting in emissions being addressed here. SCNR and SCR add-on control technologies cannot withstand temperatures generally in excess of 1000oF. Typical flare system temperatures range from 1600oF to 2000oF. Therefore SCNR and SCR add-on control technologies are not technically feasible for controlling NOx and CO emissions emitted by the proposed landfill and flare system. Step 3: Ranking remaining control technologies by control effectiveness: Combustion modification or add-on control technologies are not applicable to the proposed flare system for the reasons stated in the previous Step 2 above for both NOx and CO as minimizing NOx usually increases CO emissions. The low-NOx burner technology is incorporated in the proposed flare system designed. BCL has proposed a CO level of 0.2 lb/MMbtu. Step 4: Evaluate most effective controls and document results: Emission Controls for Existing Installations (RBLC) The BACT review requires comparison of the emissions controls proposed for the landfill expansion project sources with other similar sources. USEPA maintains a control technology database, the RBLC on - line database, that includes control technology details for various sources installed
NAAQS and PSD increment assures compliance with sensitive vegetation screening levels. The results demonstrate maximum concentrations are well below sensitive levels. It is not expected that there will be regional population, commercial, or industrial growth associated with this project. Toxics Analysis This is not applicable since the company complies with the control requirements outlined in 40 CFR Part 63, Subpart AAAA. Conclusions Based upon analysis of the permit to install application and it’s supporting documentation provided by Rumpke Landfill, Inc., the Ohio EPA staff has determined that the proposed increase will comply with all applicable State and Federal environmental regulations and that the requirements for BACT are satisfied. Therefore, the Ohio EPA staff recommends that a permit to install be issued to Rumpke Landfill, Inc.
paved or an unpaved roadway that is covered with snow and/or ice or if precipitation has occurred that is sufficient for that day to ensure compliance with the abovementioned applicable requirements. Implementation of any control measure may be suspended if unsafe or hazardous driving conditions would be created by its use. The permittee shall promptly remove, in such a manner as to minimize or prevent resuspension, earth and/or other material from paved streets onto which such material has been deposited by trucking or earth moving equipment or erosion by water or other means. Openbodied vehicles transporting materials likely to become airborne shall have such materials covered at all times if the control measure is necessary for the materials being transported. Implementation of the abovementioned control measures in accordance with the terms and conditions of this permit is appropriate and sufficient to satisfy the best available technology requirements of OAC rule 37453105(A)(3). This emissions unit is exempt from the visible particulate emission limitations specified in OAC rule 3745-17-07(B) pursuant to OAC rule 3745-17-07(B)(11)(e). This emissions unit is not located within an Appendix A area as identified in OAC rule 3745-17-08. Therefore, pursuant to OAC rule 3745-17-08(A), this emissions unit is exempt from the requirements of OAC rule 3745-17-08(B). Operational Restrictions None. Monitoring and/or Recordkeeping Requirements Except as otherwise provided in this section, the permittee shall perform inspections of the paved and unpaved roadways in accordance with the following frequencies: Paved Roadways Minimum Inspection Frequency all once daily while in operation Unpaved Roadways Minimum Inspection Frequency all once daily while in operation The purpose of the inspections is to determine the need for implementing the abovementioned control measures. The inspections shall be performed during representative, normal traffic conditions. No inspection shall be necessary for a roadway that is covered with snow and/or ice or if precipitation has occurred that is sufficient for that day to ensure compliance with the abovementioned applicable requirements. Any required inspection that is not performed due to any of the aboveidentified events shall be performed as soon as such event(s) has (have) ended, except if the next required inspection is within one week.