oregon department of environmental … department of environmental quality ... 25-0041-tv-01...

Finley BioEnergy, LLC Review Report/Permit No.: 25-0041-TV-01

Application Number: 27763

of 16

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

REVIEW REPORT

Eastern Region

475 NE Bellevue Dr., Suite 110

Bend, OR 97701

Source Information:

SIC 4911

NAICS 221119

Source Categories (Part and code) B, 27

Compliance and Emissions Monitoring Requirements:

Unassigned emissions No

Emission credits No

Compliance schedule No

Source tests [Date(s)] 18 months prior to

expiration

COMS No

CEMS No

Ambient monitoring No

Reporting Requirements

Annual report (due date) 2/15

Emission fee report (due date) 2/15

SACC (due date) 2/15, 7/30

Quarterly report (due dates) No

Monthly report (due dates) No

Excess emissions report Yes

Other reports No

Air Programs

NSPS (list subparts) A, JJJJ

NESHAP (list subparts) ZZZZ

CAM No

Regional Haze (RH) No

Synthetic Minor (SM) No

Part 68 Risk Management No

CFC No

RACT No

TACT No

Title V Yes

ACDP (SIP) No

Major HAP source No

Federal major source No

NSR No

PSD No

Acid Rain No

Clean Air Mercury Rule (CAMR) No

Review Report/Permit No.: 25-0041-TV-01


of 16

TABLE OF CONTENTS

LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT ............................................................................. 3

INTRODUCTION ......................................................................................................................................................... 4

PERMITTEE IDENTIFICATION ................................................................................................................................ 5

FACILITY DESCRIPTION .......................................................................................................................................... 5

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION ................................................... 5

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING AND RECORDKEEPING .......................... 7

PLANT SITE EMISSION LIMITS ............................................................................................................................. 10

HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 11

GENERAL BACKGROUND INFORMATION ......................................................................................................... 11

COMPLIANCE HISTORY ......................................................................................................................................... 11

SOURCE TEST RESULTS ......................................................................................................................................... 11

PUBLIC NOTICE ....................................................................................................................................................... 12

EMISSIONS DETAIL SHEETS ................................................................................................................................. 13



of 16

LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT

AQMA Air Quality Management Area

ASTM American Society of Testing and

Materials

BDT Bone Dry Ton

CEMS Continuous Emissions Monitoring

System

CFR Code of Federal Regulations

CMS Continuous Monitoring System

CO Carbon Monoxide

COMS Continuous Opacity Monitoring

System

DEQ Oregon Department of

Environmental Quality

dscf dry standard cubic feet

EF Emission Factor

EPA United States Environmental

Protection Agency

EU Emissions Unit

FCAA Federal Clean Air Act

gr/dscf grains per dry standard cubic feet

HAP Hazardous Air Pollutant

ID Identification Code

I&M Inspection and Maintenance

MB Material Balance

Mlb 1000 Pounds

MM Million

NA Not Applicable

NESHAP National Emission Standard for

Hazardous Air Pollutants

NOx Oxides of Nitrogen

NSPS New Source Performance Standard

NSR New Source Review

O2 Oxygen

OAR Oregon Administrative Rules

ORS Oregon Revised Statutes

O&M Operation and Maintenance

Pb Lead

PCD Pollution Control Device

PM Particulate Matter

PM10 Particulate Matter less than 10

microns in size

PSD Prevention of Significant

Deterioration

PSEL Plant Site Emission Limit

SO2 Sulfur Dioxide

ST Source Test

VE Visible Emissions

VMT Vehicle Mile Traveled

VOC Volatile Organic Compound



of 16

INTRODUCTION

1. This is a renewal of the Oregon Title V Operating Permit issued to Finley BioEnergy on June 16, 2010, and

scheduled to expire on June 01, 2015. A timely and complete application was submitted to the Department

so the current permit will remain in effect until the permit renewal is issued. A standard Air Contaminant

Discharge Permit (ACDP) was issued prior to the current Title V permit in 2007 to allow construction of

the facility. The ACDP permit was subsequently terminated and all applicable requirements were

transferred to the current Title V permit.

2. In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual

basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the

permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the

same as the legal basis. However, when the regulation is not specific and only provides general

requirements, this review report is used to provide a more thorough explanation of the factual basis for the

draft permit conditions.

3. There were no administrative amendments or modifications to the permit during this last permit term.

4. No engines were changed out during this last permit term or in previous permit terms. Unit 2 received an

in-frame overhaul in August 2013 that included new heads, pistons, cylinder liners and turbos.

5. Provided below is a discussion of the permit changes on a condition-by-condition basis.

New Permit

Condition

Number

Old Permit

Condition

Number

Description of Change Reason for Change

LFG Engines

Emission

Limits and

Standards

table

(following

Condition 7)

Same

Referenced condition numbers of the

table from “10” to “10.a, 10.b and 10.c”

for clarity; reference Testing Conditions

from “15” to “15.e” and “17” to “17.a,

17.b and 17.e” for clarity; and referenced

Monitoring Condition “23” to

renumbered Condition “21”.

For clarity and renumbering

Condition 12

Table Same

Added new PSELs for PM2.5 and GHG.

PSEL for CO reduced from 193 to 190

tons/yr. PSEL for VOC reduced from 67

to 58 tons/yr.

New rule requirements for PM2.5 and GHG.

PSEL reductions for CO and VOC take into

account the revised emission detail sheets at

the end of this report which take into

account the most recent source test results.

13 Same Actual assessable emissions table

removed in favor of referencing the rule.

The values of the table could potentially

change over the course of the permit term

and would require permit modification to

update the table values. Referencing the

rule only, instead, avoids this potential

permit modification need.

23.d New

Added monitoring of monthly average

percent methane content of landfill gas

consumed or combusted in each engine.

Methane content of the landfill gas may

significantly change over time impacting

operations and emissions, potentially

requiring permit modification.

26.a 26.a

Added PM2.5 Emission Factor. Changed

Emission Factors for SO2, NO2, CO and

VOC Emission Factors to take into

account 2014 source test results.

GHG and PM2.5 calculation requirements for

PSEL limits have been added to permit to

address rule changes. SO2 Emission Factor

corrected. NO2, CO and VOC Emission

Factors have been updated to average in the

2014 source test results.



of 16

New Permit

Condition

Number

Old Permit

Condition

Number

Description of Change Reason for Change

31 31 Page reference for Modified EPA Method

9 changes from Page 2 to Page 3. Actually located on Page 3

44 -- Added GHG registration and reporting

condition

Specifically call out important registration

and reporting required under OAR 340-215

and -218.

44 45 Renumbered condition. New applicable number

PERMITTEE IDENTIFICATION

6. Finley BioEnergy LLC operates a facility which burns landfill gas to create electricity.

FACILITY DESCRIPTION

7. The facility receives landfill gas from the adjacent Finley Buttes Landfill and burns the gas in large internal

combustion engines that, in turn, are used to generate electricity. Waste heat in the engine exhaust is

captured in a post-combustion heat exchanger and used to heat water. The hot water is seasonally piped to

a nearby onion drying facility to offset energy usage at that facility. The hot water is used only during the

drying season. The facility began construction on 4/30/07. Commercial operation of the engines began on

12/25/07.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

8. The emissions units, devices, activities, and pollution control devices at the facility include the following:

Emission Unit

Description EU ID Device Description Device ID

Pollution Control

Devices

Description PCD ID

Aggregate

Insignificant AI

Aggregate

Insignificant AI

None None Landfill Gas-Fired

Internal

Combustion

Engines

ENG1

(2008) Caterpillar G3520C –

2,233 Hp-hr/hr (14.1

MMBtu/hr)

CAT0000PGZJ00314

SERIAL # 9WZ00740

ENG2

(2007)

CAT0000KGZJ00315

SERIAL # 9WZ00410

ENG3

(2008)

CAT0000AGZJ00403

SERIAL # 9WZ00840

8.a. Aggregate Insignificant - Emission sources which are insignificant in aggregate include auxiliary

generators, fugitive particulate emissions from parking areas and driveways and fugitive VOC

emissions from seals, valves, flanges and blowdowns.

8.b. Emissions Units ENG1, ENG2 and ENG3 – The three Caterpillar G3520C engines are landfill

gas-fired internal combustion engines used to generate electricity. There is no air pollution control

equipment associated with the engines.



of 16

9. Categorically insignificant activities include the following:

Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound

regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or

less than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human

Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000

pounds/year

Evaporative and tail pipe emissions from on-site motor vehicle operation

Distillate oil, kerosene and gasoline fuel burning equipment rated at less than or equal to 0.4 million

Btu/hr

Office activities

Janitorial activities

Personal care activities

Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance

On-site laundry activities

Instrument calibration

Maintenance and repair shop

Automotive repair shops or storage garages

Air cooling or ventilating equipment not designed to remove air contaminants generated by or released

from associated equipment

Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated

under Title VI, including pressure tanks used in refrigeration systems but excluding any combustion

equipment associated with such systems

Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and

physical analysis, including associated vacuum producing devices but excluding research and

development facilities

Temporary construction activities

Warehouse activities

Accidental fires

Air vents from air compressors

Air purification systems

Fire suppression

Routine maintenance, repair and replacement such as anticipated activities most often associated with

and performed during regularly scheduled equipment outages to maintain a plant and its equipment in

good operating condition, including but not limited to steam cleaning, abrasive use and woodworking

Electric motors

Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual

fuels, lubricants and hydraulic fluids

Natural gas, propane and liquefied petroleum gas (LPG) storage tanks and transfer equipment

Pressurized tanks containing gaseous compounds

Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those

sources that have processes or activities that contribute to the deposition and entrainment of hazardous

air pollutants from surface soils

Health, safety and emergency response activities

Emergency generators and pumps used only during loss of primary equipment or utility service due to

circumstances beyond the reasonable control of the owner or operator, or to address a power

emergency as determined by the Department



of 16

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING AND RECORDKEEPING

10. Fugitive Emissions: OAR 340-208-0210(2) is a requirement to take reasonable precautions to minimize

fugitive particulate emissions.

10.a. Testing Requirements: By definition it is not possible to perform source emission tests on fugitive

emission sources. Therefore, the permit does not include any testing requirements or compliance

test methods for fugitive emissions.

10.b. Monitoring Requirements: The permittee is required to perform a weekly visible emissions survey

to determine if any visible emissions are leaving the plant site boundaries. If visible emissions are

observed, the permittee must take steps to minimize the fugitive emissions or conduct an EPA

Method 9 test within 24 hours to demonstrate that the opacity of the emission is less than the

standard. Records of all fugitive emission surveys and corrective measures must be kept.

11. Nuisance Conditions: OAR 340-208-0300 is a requirement that prohibits nuisance conditions and OAR

340-208-0450 prohibits particulate fallout from a source. These requirements are not part of the State

Implementation Plan (SIP) so they are only enforceable by the State. Nuisance conditions must be verified

by the Department. The permittee will be required to keep a log of any complaints and respond within a

reasonable amount of time by conducting an investigation into the source of the compliant.

12. Combusted gases at landfills are subject to the New Source Performance Standards (NSPS) 40 CFR 60

Subpart WWW for landfills. The standards of Subpart WWW do not apply to this facility because the

landfill gas is passed through a treatment system at the landfill in accordance with 40 CFR

60.752(b)(2)(iii)(C) prior to being burned in the engines.

13. The NSPS General Provisions (40 CFR 60, Subpart A) and NSPS for Stationary Spark Ignition Internal

Combustion Engines (40 CFR 60, Subpart JJJJ) are applicable to the engines at this facility.

Summary of NSPS Subpart A General Provision Requirements:

Part 60 Citation Requirement Permit Action

60.7 Notification and Recordkeeping

40 CFR 60.4246 indicates that 40 CFR 60.7 only

applies as specified in 40 CFR 60.4245. Initial

notification is required only if the engines have not

been certified by the manufacturer to meet the

emission standards in 40 CFR 60.4231. The

Caterpillar engines have been certified. No further

action required.

60.8 Performance Tests

40 CFR 60.4246 indicates that 40 CFR 60.8 only

applies to engines subject to performance testing in

Subpart JJJJ. Testing is required only if the

certified engines are not operated and maintained

according to the manufacturer’s emissions-related

written instructions. This condition will be included

in the permit.

60.11 Compliance with Standards and

Maintenance Requirements

40 CFR 60.4246 indicates these requirements are

specified in Subpart JJJJ.

60.12 Circumvention Applicable requirement contained in the permit.

60.13 Continuous Monitoring System Not applicable for this source.

60.18 General Control Device

Requirements Not applicable for this source.



of 16

Summary of NSPS Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines:

Part 60 Citation Requirement Comment

60.4230 Applicability

The engines were manufactured after 07/01/07 and

have a maximum engine power greater than 500

HP. The engines are subject to Subpart JJJJ.

60.4231 and 60.4232 Emission Standards for

Manufacturers

Not applicable. Facility does not manufacture

engines.

60.4233 Emission Standards for Owners and

Operators

Standards for landfill gas engines, >500 HP,

manufactured after 07/01/07 are 3.0 g NOx/HP-hr

(220 ppmvd @ 15% O2), 5.0 g CO/HP-hr (610

ppmvd @ 15% O2), 1.0 g VOC/HP-hr (80 ppmvd @

15% O2).

60.4234 Duration of Compliance with

Standards Must comply over entire life of engine.

60.4235 Fuel Requirements for Gasoline-

Fired Engines

Not applicable. Engines are fired only on landfill

gas.

60.4236 Deadline for Installing Engines

Manufactured Prior to 07/01/07

After 07/01/09 permittee cannot install engines that

do not meet the emission standards. This

requirement does not apply to engines that have

been modified or reconstructed or to engines

removed from one location and reinstalled at a new

location.

60.4237 Monitoring Requirements for

Emergency Engines Not applicable. Engines are not emergency engines.

60.4238 through

60.4242

Compliance Requirements for

Manufacturers

Not applicable. Facility is not an engine

manufacturer.

60.4243 Compliance Requirement for Owners

and Operators

Either purchase a certified engine and maintain

according to manufacturer’s instructions or conduct

initial testing of non-certified engine to demonstrate

compliance and subsequent tests every 8,760 hours

of engine operation or 3 years, whichever comes

first.

60.4244 Test Methods for Demonstrating

Compliance Standard EPA test methods required.

60.4245 Notification, Recordkeeping and

Reporting Requirements

Maintain records of notifications, certifications,

testing and maintenance.

60.4246 General Provisions Applicability

Identifies General Provisions applicable to

Stationary Spark Ignition Internal Combustion

Engines (identified in above table).

60.4247 Mobile Source Provisions Not applicable. Source is not mobile.

60.4248 Definitions Definitions are applicable.

14. Beginning in 2011, any owner or operator of a source required to obtain a Title V operating permit must

register and report greenhouse gases directly emitted during the previous year, if the source’s direct

emissions of carbon dioxide equivalent of greenhouse gases meet or exceed 2,500 metric tons during the

previous year. Once a source’s direct emissions of carbon dioxide equivalent of greenhouse gases meet or

exceed 2,500 metric tons during a year, the owner or operator must annually register and report in each



of 16

subsequent year. The Department calculates that the permittee has the potential to emit 20,972 metric tons

of carbon dioxide (mtCO2e) equivalent per year (20,865 biogenic and 107 anthropogenic), which is greater

than the 2,500 mtCO2e per year threshold for registering and reporting. Information submitted by Finley

BioEnergy in support of their permit renewal application indicates that the maximum 12-month total

emitted from the time the facility was placed on-line through December 2010 was 15,569 mt/CO2e (15,937

short tons/CO2e). Therefore, this permit renewal includes the addition of these requirements.

15. The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating

Internal Combustion Engines (Subpart ZZZZ) is applicable to the engines, even though the facility is not a

major source of Hazardous Air Pollutants (HAP). 40 CFR 63.6665 indicates that stationary engines located

at an area source of HAP do not need to comply with any of the requirements of the general provisions.

The engines are considered new sources since construction commenced after 06/12/06. 40 CFR 63.6590(c)

indicates that a new source located at an area source of HAP emissions must meet the requirements of 40

CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ. No further requirements

apply for such engines under the NESHAP.

16. 40 CFR Part 68: Accidental Release Prevention Regulations do not apply to the facility at this time, as

there are no substances stored or used at the facility in threshold quantities, however this condition will be

included in the permit in case the facility does trigger this requirement in the future.

17. The RACT rules are not applicable to this source because it is not in the Portland AQMA, Medford AQMA

or Salem SKATS.

18. The Department has determined that the engines are not subject to the Typically Available Control

Technology requirements in Division 226 because the engines are subject to the New Source Performance

Standards for internal combustion engines (40 CFR Part 60, Subpart JJJJ).

19. As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include

categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-

0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter

(0.1 gr/dscf limit). The Department does not consider it likely that IEUs could exceed an applicable

emissions limit or standard because IEUs are generally equipment or activities that do not have any

emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions.

Since there are no controls, no visible emissions, and the emissions are less than one ton per year, the

Department does not believe that monitoring, recordkeeping or reporting is necessary for assuring

compliance with the IEU standards.



of 16

PLANT SITE EMISSION LIMITS

20. Provided below is a summary of the baseline emissions rate, netting basis, plant site emission limits and

emissions capacity.

Pollutant

Baseline

Emission

Rate

(tons/yr)

Netting Basis Plant Site Emission Limit (PSEL)

Previous

PSEL

(tons/yr)

Proposed

PSEL

(tons/yr)

PSEL

Increase

(tons/yr) Previous

(tons/yr)

Proposed

(tons/yr)

PM 0 0 0 24 24 0

PM10 0 0 0 14 14 0

PM2.5 0 NA 0 NA 9 9

CO 0 0 0 193 190 -3

NOx 0 0 0 39 39 0

SO2 0 0 0 39 39 0

VOC 0 0 0 67 58 -9

GHG 14,942 NA 14,942 NA 74,000 74,000

20.a. The baseline emission rate and the proposed netting basis are zero for all pollutants except GHG

because this facility was constructed after the baseline period (1977-1978) and has not been

subject to New Source Review (NSR).

20.b. The proposed PSEL for all pollutants except CO and VOC are equal to the Generic PSEL in

accordance with OAR 340-222-0040(1).

20.c. The proposed PSELs for CO and VOC are greater than the generic levels. These proposed PSELs

take into account additional source test data. The proposed PSEL for CO is less than the previous

permit by 3 tons, whereas the proposed VOC PSEL is 9 tons less. There were no physical changes

or changes in the methods of operation that contributed to these changes.

20.d. The netting basis for PM2.5 is based on the PM2.5 fraction of the PM10 netting basis in effect on

May 1, 2011 in accordance with the definition of netting basis in OAR 340-200-0020.

20.e. For GHG, the baseline emission rate and netting basis are based on actual greenhouse gas

emissions during any consecutive 12-month period during calendar years 2000 through 2010. The

facility’s maximum actual emissions were experienced during the 2010 calendar year.

SIGNIFICANT EMISSION RATE

21. The PSELs for PM, PM10, PM2.5, NOx, SO2 and GHGs are not greater than the netting basis by more than

the significant emission rate. Thus, no further air quality analysis is required for these pollutants and the

PSELs are approved as established in previous permitting actions. The PSEL for CO and VOC is greater

than the netting basis by more than the significant emission rate. As explained below the facility is not

considered a federal major source and, therefore, is not subject to New Source Review (NSR) or Prevention

of Significant Deterioration (PSD) rules. In accordance with OAR 340-222-0041(3)(b)(C) an air quality

analysis was previously conducted which demonstrated compliance with the National Ambient Air Quality

Standards (NAAQS) and PSD increments. This modeling was discussed in the initial ACDP issued on

October 16, 2007. The results of this analysis are still valid.

22. Since the emissions of each pollutant are less than 250 tons/year, the facility is not a federal major source

as defined in OAR 340-200-0020. A Best Available Control Technology (BACT) analysis under the

federal Prevention of Significant Deterioration (PSD) rules is not required for sources that are not a federal

major source



of 16

HAZARDOUS AIR POLLUTANTS

23. A major source is a facility that has the potential to emit more than 10 tons/year of any single HAP or 25

tons/year of combined HAPs. This source is not a major source of Hazardous Air Pollutants. A summary

of HAP emission are calculated and presented in the Emission Detail Sheets at the end of this report.

GENERAL BACKGROUND INFORMATION

24. This Title V Permit will replace the previous Title V Permit. The ACDP Permit that was issued prior to the

Title V Permit will continue to exist for historical enforcement purposes and as a basis for determining

applicable requirements.

25. No other permits have been issued or are required by the Department of Environmental Quality for this

source.

26. The source is located in an attainment area for all pollutants.

27. The facility is located more than 100 kilometers (62 miles) from any Class I wilderness area.

COMPLIANCE HISTORY

28. The facility was inspected on the following dates during the last permit term:

Inspection Date Results of Inspection Department Actions

9/23/2010

In Compliance No Action Necessary 8/21/2012

9/25/2014

SOURCE TEST RESULTS

29. Emission factor test results, averages, variability (% change), and proposed new permit emission factors

provided below:

Engine 1 Engine 2 Engine 3

Test

Date

NOx CO VOC1 Test

Date

NOx CO VOC1 Test

Date

NOx CO VOC1

(lbs/MMscf) (lbs/MMscf) (lbs/MMscf)

2/20/2008 66.4 487.9 151.1 2/20/2008 61.4 461.1 131.4 1/20/2009 58.6 433.7 16.92

4/08/2014 57.3 360.2 200.9 4/08/2014 52.9 286.1 211.9 4/09/2014 60.1 389.6 173.0

Ave. &

Change

61.9

(13.7%)

424.1

(26.2%)

176.0

33.0%

Ave. &

Change

57.2

(13.8%)

373.6

(38%)

171.7

61.3%

Ave. &

Change

59.4

2.6%

411.7

(10.2%)

157.23

(22.4%)

Proposed4 61.9 487.9 151.1 Proposed4 57.2 461.1 131.4 Proposed4 59.4 433.7 141.3

Note 1: As propane

Note 2: Review of the source test result for Engine #3 VOC reveals that this value was incorrectly calculated using bag method results

for THC as opposed to a Flame Ionization Detector (FID) method result for THC, from which bag method result of combined methane

and ethane are to be subtracted to arrive at the VOC result. Bag method determination of THC is unreliable, and quite likely produced a

significantly erroneous value. This 16.9 value is being considered as invalid and not to be used for averaging and determination of the

new and future VOC emission factors for Engine 3. The average VOC of Engines 1 and 2 in April 2008 was 141.3, which is being

proposed as the emission factor for Engine 3.

Note 3: The average and % change incorporates the 141.3 value as discussed in Note 2.

Note 4: Proposed NOx emission rates are based upon an average of tested values in 2008 and 2014. Since the variability (% change) of

the CO and VOC tested emissions were highly variable, DEQ proposes that the generally more conservative 2008 derived emission

factors be carried forward until such time as more test results are available and are considered representative.



of 16

PUBLIC NOTICE

30. This permit was placed on public notice from February 21, 2015 to March 30, 2015. No comments were

received in response to the public notice and no changes have been made to the permit. A proposed permit

will be sent to EPA for a 45 day review period. DEQ may request and EPA may agree to an expedited

review of 5 days if there were no substantive or adverse comments during the comment period.

If EPA does not object in writing, any person may petition the EPA within 60 days after the expiration of

EPA's 45-day review period to make such objection. Any such petition must be based only on objections

to the permit that were raised with reasonable specificity during the public comment period provided for in

OAR 340-218-0210, unless the petitioner demonstrates it was impracticable to raise such objections within

such period, or unless the grounds for such objection arose after such period.



of 16

EMISSIONS DETAIL SHEETS

PM/PM10/PM2.5

Emission

Point Operating Parameters

Emission Factor Emissions

tons/yr Rate Reference

ENG#1 275.4 MMdscf LFG/yr 7.5 lb/MMdscf LFG AP-42 Table 2.4-4 1.0

ENG#2 275.4 MMdscf LFG/yr 7.5 lb/MMdscf CH4 AP-42 Table 2.4-4 1.0

ENG#3 275.4 MMdscf LFG/yr 7.5 lb/MMdscf CH4 AP-42 Table 2.4-4 1.0

Total Particulate Emissions 3.0

SO2

Emission




ENG#1 275.4 MMdscf LFG/yr 8.3 lb/MMdscf LFG Manufacturer Data 1.1



Total SO2 Emissions 3.3

NOx

Emission




ENG#1 275.4 MMdscf LFG/yr 61.9 lb/MMdscf LFG Stack Test Average 8.5



Total NOx Emissions 24.6

CO

Emission



ton/yr Rate Reference

ENG#1 275.4 MMdscf LFG/yr 487.9 lb/MMdscf LFG 2008 Stack Test 67.2



Total CO Emissions 190.4



of 16

VOC

Emission







Total VOC Emissions 58.4

HAP

Pollutant Combined Engine

Rating Emission Factor

Emissions (ton/yr)

1,1,1-Trichloroethane 6699 hp-hr/hr 4.48E-08 lb/hp-hr 1.31E-03

1,1,2,2-Tetrachloroethane 6699 hp-hr/hr 1.29E-07 lb/hp-hr 3.79E-03

1,1-Dichloroethane 6699 hp-hr/hr 1.66E-07 lb/hp-hr 4.87E-03

1,1-Dichloroethene 6699 hp-hr/hr 1.35E-08 lb/hp-hr 3.96E-04

1,2-Dichloroethane 6699 hp-hr/hr 2.82E-08 lb/hp-hr 8.27E-04

1,2-Dichloropropane 6699 hp-hr/hr 1.42E-08 lb/hp-hr 4.17E-04

Acrylonitrile 6699 hp-hr/hr 2.34E-07 lb/hp-hr 6.87E-03

Benzene - co-disposal 6699 hp-hr/hr 6.00E-07 lb/hp-hr 1.76E-02

Benzene - other 6699 hp-hr/hr 1.03E-07 lb/hp-hr 3.02E-03

Carbon disulfide 6699 hp-hr/hr 3.09E-08 lb/hp-hr 9.07E-04

Carbon tetrachloride 6699 hp-hr/hr 4.30E-10 lb/hp-hr 1.26E-05

Carbonyl sulfide 6699 hp-hr/hr 2.05E-08 lb/hp-hr 6.02E-04

Chlorobenzene 6699 hp-hr/hr 1.96E-08 lb/hp-hr 5.75E-04

Chloroethane 6699 hp-hr/hr 5.84E-08 lb/hp-hr 1.71E-03

Chloroform 6699 hp-hr/hr 2.49E-09 lb/hp-hr 7.31E-05

Dichloromethane 6699 hp-hr/hr 8.29E-07 lb/hp-hr 2.43E-02

Ethylbenzene 6699 hp-hr/hr 3.40E-07 lb/hp-hr 9.98E-03

Ethylene dibromide 6699 hp-hr/hr 1.31E-10 lb/hp-hr 3.84E-06

Hexane 6699 hp-hr/hr 3.97E-07 lb/hp-hr 1.16E-02

Mercury 6699 hp-hr/hr 4.06E-11 lb/hp-hr 1.19E-06

Methyl ethyl ketone 6699 hp-hr/hr 3.57E-07 lb/hp-hr 1.05E-02

Methyl isobutyl ketone 6699 hp-hr/hr 1.33E-07 lb/hp-hr 3.90E-03

Perchloroethylene 6699 hp-hr/hr 4.28E-07 lb/hp-hr 1.26E-02

Toluene - co-disposal 6699 hp-hr/hr 1.09E-05 lb/hp-hr 3.20E-01

Toluene - other 6699 hp-hr/hr 2.51E-06 lb/hp-hr 7.36E-02

Trichloroethylene 6699 hp-hr/hr 2.56E-07 lb/hp-hr 7.51E-03

Vinyl chloride 6699 hp-hr/hr 3.17E-07 lb/hp-hr 9.30E-03

Xylenes 6699 hp-hr/hr 8.88E-07 lb/hp-hr 2.61E-02

Total HAP 5.52E-01

HAP emission factors are from EPA’s LANDGEM model. Assumes 550 scfm LFG is used to produce 2233 hp and

assumes a 98% DRE in the engines.



of 16

GHG Potential to Emit calculation - Fuel combustion greenhouse gas calculator - Finley BioEnergy

This sheet calculates greenhouse gas 1) Enter the combustion 2) In the 2nd column, select the fuel type used in each emissions unit. If more than 3) Enter the fuel quantities in the 3rd column and specify emissions from fuel combustion. emission sources at the facility one fuel type was used in a single emissions unit, you must enter that same the unit of measure in the 4

th column. Emissions are then

(e.g. "boiler 1") in the 1st

column. emissions unit on multiple rows and then enter the different fuel types in each

row. calculated in metric tons of carbon dioxide equivalent

(mtCO2e).

Enter emissions information

Emissions unit1

Fuel Type2

Quantity3

Fuel units3

Convert to mmBtu

HHV Units HHV Unit HHV mmBtu

Emissions (kg/mmBtu)

CH4 CO2 N2O

CO2 Equivalent

CH4 CO2 N2O

Anthropogenic (mtCO2e)

CH4 CO2 N2O

Biogenic

(mtCO2e)

Engine 1 Bio Gas 275 Million cubic ft 275,400,000 cubic ft 0.00049 133,569 0.0032 0 0.00063 25 1 298 11 0 25 6,955



0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

mtCO2e Short Tons CO2e

Anthropogenic combustion emissions:

Biogenic combustion emissions:

107

20,865

118

23000

Total combustion emissions (all 3 Engines): 20,972 23,118

Single engine emissions: 6,991 7,706

1 of 1



of 16

GHG Baseline Calculation (based upon 2010) - Fuel combustion greenhouse gas calculator - Finley BioEnergy

This sheet calculates greenhouse gas 1) Enter the combustion 2) In the 2nd column, select the fuel type used in each emissions unit. If more than 3) Enter the fuel quantities in the 3rd column and specify emissions from fuel combustion. emission sources at the facility one fuel type was used in a single emissions unit, you must enter that same the unit of measure in the 4

th column. Emissions are then

(e.g. "boiler 1") in the 1st

column. emissions unit on multiple rows and then enter the different fuel types in each

row. calculated in metric tons of carbon dioxide equivalent

(mtCO2e).

Enter emissions information

Emissions unit1

Fuel Type2

Quantity3

Fuel units3

Convert to mmBtu

HHV Units HHV Unit HHV mmBtu

Emissions (kg/mmBtu)

CH4 CO2 N2O

CO2 Equivalent

CH4 CO2 N2O

Anthropogenic (mtCO2e)

CH4 CO2 N2O

Biogenic

(mtCO2e)




0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

0 0 0 0 0 0 0 25 1 298 0 0 0 0

mtCO2e Short Tons CO2e

Anthropogenic combustion emissions:

Biogenic combustion emissions:

69

13,486

76

14865

Total combustion emissions (all 3 engines): 13,555 14,942

Single engine emissions: 4,518 4,981

oregon department of environmental … department of environmental quality ... 25-0041-tv-01...

Documents