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Hag- <br /> ALMES & ASSOCIATES, INC. coy'P <br /> -Al CONSULTING ENGINEERS <br /> 111 COMMONWEALTH COURT, SUITE C4. CA V, NC 2751'-446: <br /> PHONE: (919) ?,19-118 7 TAX: (419)481-1522 <br /> August 25, 1998 <br /> Project No: R97-945-595 <br /> Mr.Thomas C. Allen, II <br /> Environmental Engineering Supervisor <br /> NC DEHNR Division of Air Quality <br /> P.O. Box 29580 <br /> Raleigh, North Carolina 27626-0580 <br /> Transmittal <br /> Recalculation of NMOC Emissions for Title V Applicability <br /> Orange Regional Landfill(MSWLF Permit No. 68-01) <br /> Chapel Hill,North Carolina <br /> Dear Mr. Allen: <br /> On behalf of the Town of Chapel, North Carolina, Almes& Associates, Inc. (ALMES) has <br /> recalculated the rate of past and future Non-Methane Organic Compound(NMOC) emissions for <br /> the Orange Regional Landfill. The Landfill is composed of two distinct MSW disposal units <br /> located on separate tracts bisected by Eubanks Road. The Northern and Southern MSW disposal <br /> units of the Orange Regional Landfill have been considered a single emissions source in our <br /> evaluations. <br /> This work fulfills the requirements of the second option stated in your letter to Orange Regional <br /> Landfill dated December 1, 1997. Specifically, those options were to either: 1) submit an <br /> application for a Title V operating permit or 2) submit additional landfill documentation and <br /> recalculation of NMOC emissions demonstrating that the solid waste facility's potential to emit <br /> regulated air pollutants is below the 100 ton/year Title V applicability threshold. The North <br /> Carolina Department of Environment&Natural Resources, Division of Air Quality's(DAQ) <br /> request for further facility documentation and/or permitting was based on the results of the <br /> DAQ's calculations of late 1997. The DAQ's calculations, based on information provided in the <br /> Initial Design Capacity Report, suggested elevated landfill air emissions rates for Orange <br /> Regional Landfill (Table 1). <br /> A general time extension was granted by the DAQ to a number of MSW landfills, including <br /> Orange Regional Landfill, following concerns with the short response period, the accuracy of the <br /> DAQ's December landfill emission estimates, and potential for misinterpretation of the data <br /> presented in the Initial Design Capacity Report. Most notable, the DAQ's calculations were_. <br /> partially based on the very conservative model and default gas generation factors promulgated to <br /> evaluate NSPS applicability rather than the AP-42 default factors published for Title V purposes. <br />