Post on 13-Mar-2018
Finley BioEnergy, LLC Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 1 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
Application Number: 27763
Page 2 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
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 3 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
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 4 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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 5 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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 6 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
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 7 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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 8 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
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 9 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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 10 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
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 11 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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 12 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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 13 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
Point Operating Parameters
Emission Factor Emissions
tons/yr Rate Reference
ENG#1 275.4 MMdscf LFG/yr 8.3 lb/MMdscf LFG Manufacturer Data 1.1
ENG#2 275.4 MMdscf LFG/yr 8.3 lb/MMdscf LFG Manufacturer Data 1.1
ENG#3 275.4 MMdscf LFG/yr 8.3 lb/MMdscf LFG Manufacturer Data 1.1
Total SO2 Emissions 3.3
NOx
Emission
Point Operating Parameters
Emission Factor Emissions
tons/yr Rate Reference
ENG#1 275.4 MMdscf LFG/yr 61.9 lb/MMdscf LFG Stack Test Average 8.5
ENG#2 275.4 MMdscf LFG/yr 57.2 lb/MMdscf LFG Stack Test Average 7.9
ENG#3 275.4 MMdscf LFG/yr 59.4 lb/MMdscf LFG Stack Test Average 8.2
Total NOx Emissions 24.6
CO
Emission
Point Operating Parameters
Emission Factor Emissions
ton/yr Rate Reference
ENG#1 275.4 MMdscf LFG/yr 487.9 lb/MMdscf LFG 2008 Stack Test 67.2
ENG#2 275.4 MMdscf LFG/yr 461.1 lb/MMdscf LFG 2008 Stack Test 63.5
ENG#3 275.4 MMdscf LFG/yr 433.7 lb/MMdscf LFG 2008 Stack Test 59.7
Total CO Emissions 190.4
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 14 of 16
VOC
Emission
Point Operating Parameters
Emission Factor Emissions
tons/yr Rate Reference
ENG#1 275.4 MMdscf LFG/yr 151.1 lb/MMdscf LFG 2008 Stack Test 20.8
ENG#2 275.4 MMdscf LFG/yr 131.4 lb/MMdscf LFG 2008 Stack Test 18.1
ENG#3 275.4 MMdscf LFG/yr 141.3 lb/MMdscf LFG 2008 Stack Test 19.5
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.
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 15 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
Engine 2 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
Engine 3 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
Review Report/Permit No.: 25-0041-TV-01
Application Number: 27763
Page 16 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)
Engine 1 Bio Gas 178 Million cubic ft 178,000,000 cubic ft 0.00049 86,330 0.0032 0 0.00063 25 1 298 7 0 16 4,495
Engine 2 Bio Gas 178 Million cubic ft 178,000,000 cubic ft 0.00049 86,330 0.0032 0 0.00063 25 1 298 7 0 16 4,495
Engine 3 Bio Gas 178 Million cubic ft 178,000,000 cubic ft 0.00049 86,330 0.0032 0 0.00063 25 1 298 7 0 16 4,495
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