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MAJOR FACILITY REVIEW PERMIT Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109
(415) 771-6000




Permit Evaluation and
Statement of Basis

MAJOR FACILITY REVIEW PERMIT
MINOR REVISION

for
Kirby Canyon Landfill
Facility #A1812


Facility Address:
910 Coyote Creek Golf Drive
Morgan Hill, CA

Mailing Address:
P.O. Box 1870
Morgan Hill, CA 95038

Application #: 14076

September 2006



Application Engineer: Robert Hull

Title V Minor Revision

A. Background
The Kirby Canyon Landfill (S-1) is an active 311-acre Class III landfill located approximately
15 miles south of downtown San Jose, adjacent to U.S. Highway 101. The facility accepts non-
hazardous residential, commercial, industrial, and inert wastes. The landfill has an estimated
closure date of June 2018. This landfill is equipped with an active gas collection system (a
system of pipes and blowers) that includes approximately 36 vertical gas collection wells. The
wells are perforated sections of the pipes that are buried in the refuse at various locations. The
blowers collect landfill gas by creating a vacuum in the buried refuse that draws landfill gas into
the perforated pipes. The blowers vent the collected landfill gas to an enclosed flare (A-11).

This facility is subject to the Operating Permit requirements of Title V of the federal Clean Air
Act, Part 70 of Volume 40 of the Code of Federal Regulations (CFR), and BAAQMD Regulation
2, Rule 6, Major Facility Review because it is a designated facility as defined by BAAQMD
Regulation 2-6-204. The Emission Guidelines for Municipal Solid Waste Landfills (40 CFR
Part 60, Subpart Cc) requires the owner or operator of a landfill that is subject to this part and
that has a design capacity greater than or equal to 2.5 million megagrams and 2.5 million cubic
meters to obtain an operating permit pursuant to Part 70.

Major Facility Operating permits (Title V permits) must meet specifications contained in 40
CFR Part 70 as contained in BAAQMD Regulation 2, Rule 6. The permits must contain all
applicable requirements (as defined in BAAQMD Regulation 2-6-202), monitoring
requirements, recordkeeping requirements, and reporting requirements. The permit holders must
submit reports of all monitoring at least every six months and compliance certifications at least
every year.

In the Bay Area, state and District requirements are also applicable requirements and are
included in the permit. These requirements can be federally enforceable or non-federally
enforceable. All applicable requirements are contained in Sections I through VI of the permit.

Each facility in the Bay Area is assigned a facility number that consists of a letter and a 4-digit
number. This facility number is also considered to be the identifier for the permit. The facility
number for the Kirby Canyon Landfill is A1812.

The Kirby Canyon Landfill was issued an initial Title V permit on July 10, 2003 and Minor
Permit Revisions on January 12, 2005 and July 13, 2006. This application is also for a Minor
Permit Revision to add a diesel powered portable air compressor to the permit.

B. Summary of Proposed Permit Revision

Kirby Canyon Landfill was issued a BAAQMD Permit to Operate the following equipment on
May 15, 2006 under Permit Application #14010: (see attached Engineering Evaluation Report) S-8: Portable Diesel IC Engine Air Compressor; John Deere Model 4045D, 80 BHP

The purpose of this Minor Permit Revision is to incorporate this source and its applicable
requirements into the Title V permit.

C. Emissions
Increase

Based on assumptions made during the evaluation, the Portable Diesel IC Engine S-8 will
potentially increase emissions at the facility as follows:

NOx = 0.580
tons/yr
CO =
0.263
tons/yr
POC = 0.031
tons/yr
PM10 = 0.027
tons/yr
SO
2
= 0.014
tons/yr

D. Monitoring
Analysis

Portable Diesel IC Engine Compressor S-8
The Portable Diesel I.C. Engine S-8 is subject to the requirements of BAAQMD Regulation 6
Particulate Matter and Visible Emissions BAAQMD Regulation 9, Rule 1 Inorganic Gaseous
Pollutants Sulfur Dioxide and the CARB ATCM For Diesel Particulate Matter From Portable
Engines.

Particulate Matter and Visible Emissions:
BAAQMD Regulation 6-310 limits PM emissions to 0.15 gr/dscf. If it is assumed that the diesel
engine exhaust gases contain 15% excess oxygen under normal operating conditions, the
Regulation 6-310 limit can be compared to the CARB certified PM emission factor for S-8 (0.24
g/bhp-hr) as follows:

From 40 CFR 60, Appendix A, Method 19, Table 19-1, a stoichiometric dry gas combustion
factor of 9,190 dscf/MMBTU is given for distillate oil combustion. At 15% excess O
2
this factor
becomes:


9,190 x [21%/(21% - 15%)] = 32,165 dscf (combustion products)/MMBTU

The conversion of 0.15 gr/dscf @ 15% O
2
to lb/MMBTU is then:


(32,165 dscf/MMBTU) x (0.15 gr/dscf) x (lb/7,000 gr) = 0.689 lb/MMBTU

Based on the fuel consumption rate for S-8 (i.e. 0.45 MMBTU/hr), the certified PM emission
rate in terms of fuel consumption is 0.09 lb/MMBTU. Since the PM emission rate is well below
the converted Regulation 6-310 emission rate in each case, compliance is assumed.

Compliance with the Ringelmann 2.0 limit of Regulation 6-303.1 is expected based on the
CARB certified Diesel PM emissions for this engine model. Added monitoring is not necessary to reasonably assure compliance with the applicable
Regulation 6 requirements.

SO
2
Emissions
Regulation 9-1-304 requires all liquid fuels to have a sulfur content <0.5% (wt). In addition,
Section 93116.3(a) of the CARB ATCM For Portable Diesel Engines requires the use of CARB
Diesel Fuel (or verified alternative) for all portable diesel engines >50 bhp. The use of CARB
Diesel Fuel (sulfur content <0.05% wt.) will be made a condition of the permit for S-8. Vendor
fuel sulfur content certifications will be required to demonstrate compliance with this limit. (see
Condition #23022 in Section E, below)

NMHC, NOx, CO, and Diesel PM
Section 93116.3(b)(2) of the ATCM For Portable Diesel Engines requires emissions from
engines that have not been permitted or registered prior to January 1, 2006 to meet the most
stringent of the federal or California emission standards for newly manufactured nonroad
engines. For S-8, the applicable tier II (>50 - <100 hp) standards compare to the CARB certified
emissions (Executive Order U-R-004-0231) as follows:

Pollutant

Tier II Standard
(g/bhp-hr)
CARB Certified Emissions for S-8
(g/bhp-hr)
NOx + NMHC
5.6
5.37
CO 3.7 3.31
PM 0.30 0.24

Since the certified emissions from S-8 meet the applicable Tier II standards, a demonstration of
compliance with ATCM Section 93116.3(b)(2) is fulfilled and no additional monitoring is
required.

Facility-Wide NOx Limit
Using the traditional permitting methodology of calculating a cumulative emissions increase for
the new source and providing offsets as required by Regulation 2-2-302 (including
reimbursement of offsets previously provided by the Small Facility Banking Account), it was
concluded that Kirby Canyon would need to provide 27.107 tons of NOx offsets in order to
obtain a permit for the Portable Diesel IC Engine Compressor S-8. As this seems excessive for
the addition of a small source, an alternative permitting strategy is proposed as follows:

The Kirby Canyon Landfill is currently permitted for NOx emissions up to 40.9 tons/yr. This
total assumes that the Landfill Gas Flare A-11 and the Landfill Gas Fired IC Engines S-5, S-
6, and S-7 all operate continuously at maximum capacity. However, in reality there is not
currently enough landfill gas generated to fire all 3 engines and the flare at the same time.

The landfill gas collection system currently collects approximately 1,200 cfm of landfill gas,
which is then combusted in the Flare A-11 (Capacity = 1,480 cfm). The (3) LFG IC Engines
were issued an Authority to Construct on 9/17/04 (Application #9220), but have not yet
started operating. These engines each have a landfill gas capacity of 345.3 cfm, for a total of
1,036 cfm. Therefore, the combined capacity of the flare and engines is 2,516 cfm, more than
twice the amount that is currently processed.
Based on the underutilized capacity of the landfill gas combustion devices, it is clear that
facility NOx emissions are well below the permitted total. It is therefore recommended that a
facility-wide NOx limit be imposed, rather than requiring NOx offsets at this time. It is
anticipated that Kirby Canyon could easily operate under a facility-wide NOx limit of 40.9
tons/yr for some time to come. Of course if this limit were ever exceeded, Kirby Canyon
would be required to provide all required offsets.

Changes to monitoring to implement a facility-wide NOx limit will be made by adding a new
permit condition requiring NOx emissions