6.3. ERMUSR 10-09-2007 - Laserfiche WebLink

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September 14, 2007 Mr. Bryan Adams Elk River Municipal Utilities 422 King Avenue Elk River, MN 55330 Re: Proposal for Air Quality Services Related to the Installation and Operation of a Second Landfill Gas (LFG)-to-Energy Plant at Waste Management's Elk River Landfill. Dear Mr. Adams: In response to your telephone request of September 4, 2007, I am pleased to submit an updated version of our July 3, 2007 proposal for air quality services for the Elk River Municipal Utilities (ERML7) and the Elk River Landfill (ERL). Background Waste Management Inc. (WMI) currently operates four Caterpillar 3516 engines in aLFG-to-Energy Plant located at the Elk River Landfill. The first three engines were permitted in 2001 and began operation in November 2002. The fourth engine received a moderate permit amendment in 2006 (air permit 141000041-004, issued January 18, 2006) and began operation in July 2006. To process landfill gas expected to be generated by a significant expansion of the landfill to the south, WMI intends to install a second LFG-to-Energy Plant that will initially house four additional engines but will be built to accommodate up to eight engines. Each new engine will be identical to the those in place in the existing LFG-to-Energy Plant. There are several regulatory thresholds that could drive the air permitting of the second LFG-to-Energy Plant: NSR-PSD (40 CFR 52.21) The federal New Source Review (NSR) -Prevention of Significant Deterioration (PSD) program requires that the emissions of certain regulated pollutants from a proposed project be quantified and compared to threshold values. Since (i) the existing landfill is not a "major stationary source" under NSR and (ii) MSW landfills are not listed in 40 CFR 52.21(b)(1)(i)(a), the threshold of concern is 250 tons/yr of CO, NOx, PM, PM10, S02, VOC, Lead, NMOC etc. The PSD rules specify the calculation methods that must be used to estimate emissions for comparison to the thresholds. EAW (Minn. R. 4410.1000) The most likely threshold for a mandatory Environmental Assessment Worksheet (EAW) is 250 tons/year of any single air pollutant, after installation of air pollution control equipment, per Minn. R. 4410.4300, subpart 15.