TITLE V AIR OPERATION PERMIT RENEWAL

2022 Tier 2 NMOC
Emission Rate Report
Lake County Central Solid Waste
Management Facility
Prepared for:
Lake County Public Works Solid Waste Division
13130 County Landfill Road
Tavares, FL 32788
Prepared by:
HDR Engineering, Inc.
4401 West Gate Boulevard,
Austin, TX 78745
August 2022

Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
Table of Contents
Introduction.................................................................................................................................................... 2
Site Information ............................................................................................................................................. 2
Sampling Methodology .................................................................................................................................. 2
Description of Sampling Equipment .................................................................................................... 3
Sampling Locations ............................................................................................................................. 3
Field Sampling Procedures ................................................................................................................. 3
Summary of Laboratory Analysis .................................................................................................................. 5
Tier 2 NMOC Emission Estimate .................................................................................................................. 5
Waste Disposal Rates ......................................................................................................................... 6
Model Parameters ............................................................................................................................... 6
NMOC Emission Estimate Model Results ........................................................................................... 6
Conclusion and Recommendations .............................................................................................................. 6
Figures
Figure 1 - Capped Phase 1 Vent with Sample Tubing ................................................................................. 4
Tables
Table 1 - Summary of Laboratory Results ................................................................................................... 5
Table 2 - EPA LandGEM Model Output ....................................................................................................... 6
Appendix
Appendix A - Landfill Gas Sampling Locations ............................................................................................ 8
Appendix B - Field Data Forms .................................................................................................................... 9
Appendix C - Laboratory Results and Quality Control Data ....................................................................... 10
Appendix D - EPA LandGEM Summary Report ......................................................................................... 11
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
Introduction
HDR Engineering, Inc. (HDR) has been retained by S2L, incorporated (S2Li), on behalf of the Lake
County Public Works Solid Waste Division, to conduct landfill gas (LFG) sampling and analysis at the
Lake County Central Solid Waste Management Facility (LCCSWMF) located in Tavares, Florida. The
purpose of this investigation is to obtain site-specific non-methane organic compound (NMOC) values
to be used in NMOC emissions modeling required under the landfill New Source Performance
Standards and Emission Guidelines (NSPS/EG) regulations.
NSPS/EG regulations currently promulgated under the new Federal Plan (Title 40 Code of Federal
Regulations (CFR) Subpart OOO) are applicable for the LCCSWMF. As of the date of this report, it
should be noted that the Federal Register/Vol. 86, No. 205, published on October 27, 2021, indicates
the Environmental Protection Agency (EPA) is proposing to approve a Clean Air Act (CAA) section
111(d) plan submitted by the Florida Department of Environmental Protection (FDEP) on December
22, 2020. This action would allow for promulgation of the EG regulations (40 CFR Subpart Cf) in
Florida (and the LCCSWMF). Notwithstanding this anticipated action, sampling was conducted in
accordance with the requirements outlined in both the Subpart OOO and Subpart Cf regulations, as
they are identical with respect to this sampling protocol. Specifically, these regulations refer to the
sampling methodologies described in EPA Method 3C and EPA Method 25C.
Site Information
The LCCSWMF began accepting municipal solid waste (MSW) in 1972. Since this time, MSW (as well
as incinerator ash) has been disposed of in the Phase I, II, and III landfills. The Phase I landfill is the
oldest and largest landfill cell. Phase I has a total waste area of approximately 80 acres and was
formally closed in 1993 with a flexible membrane final cover system.
The Phase II landfill was constructed in different sequences: (a) Phase IIA landfill, which received only
incinerator ash from the Waste to Energy (WTE) plant; (b) Phase IIB landfill, which received MSW and
incinerator ash; (c) Phase IIC landfill, which received MSW and incinerator ash; and (d) Phase II
Vertical Expansion, which also received MSW and incinerator ash. Phase II encompasses
approximately 15 acres and was formally closed in 2016 with a flexible membrane final cover system.
The Phase III Landfill (MSW Cell and Ash Cell) was permitted in 2006 and certified by FDEP for waste
disposal in 2010. The Phase III landfill started receiving WTE ash in February 2011. It is understood
that MSW and ash have been commingled in Phase III since 2001, with the last waste receipt being
in 2016. Phase III is approximately 5 acres, and has not yet formally undergone final capping and
closure.
Sampling Methodology
Tier 2 field sampling activities were conducted at the LCCSWMF on Monday July 25, 2022 through
Thursday July 28, 2022 by Joel Miller, PE and Chelsea Williams, EI of HDR. Three representatives of
the LFG drilling subcontractor, Preferred Drilling Solutions, Inc. (PDS), were on site Monday July 25,
2022 for Phase III sampling activities. Sampling was performed according to the procedures outlined
in the previously-submitted Sampling Plan, and in accordance with EPA Method 25C.
The LFG samples were composited into stainless steel Summa canisters per Method 25C. In total,
thirty (30) sample locations (26 sample locations and four duplicates) were composited into 13
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
canisters, with a maximum of 3 sample locations per canister. The samples were transferred to
Atmospheric Analysis and Consulting, Inc. (AAC) in Ventura, California for subsequent analysis under
EPA Methods 3C and 25C.
Description of Sampling Equipment
EPA Reference Method 25C, "Determination of NMOC in MSW Landfill Gases", was followed for the
Tier 2 sampling effort as required by NSPS/EG with the exception of two EPA-approved minor
modifications as described in the Sampling Plan. The two minor modifications to Method 25C included
use of the Geoprobe(R) Post-Run Tubing System (post-run tubing system) for Phase III sampling, and
the use of a constant rate flow controller instead of a rotameter in the sampling train. These minor
modifications were described in the Sampling Plan and approved by precedent per the EPA letter
provided in that document.
For all sample locations, the source of LFG and tubing system was connected to a sampling train that
included a 3-way purge/sample valve, calibrated Landtec model GEM-2000 portable LFG analyzer
(GEM-5000 used on first day of sampling), and a constant rate flow controller and vacuum gauge. The
flow controller for this sampling was set at a constant rate of approximately 200 milliliters per minute
(mL/min) by the laboratory prior to shipment. This meets the requirement in the method for sampling
at a flow rate of less than 500 mL/min.
Sampling Locations
Consistent with the Sampling Plan and the methodology for lined cells, existing passive vents in
Phase I and Phase II were sampled in order to preserve the integrity of the flexible membrane liner on
these capped and closed cells. Due to the age and composition of the waste in these cells, extra care
was taken to capture representative LFG samples from these cells. As discussed in below sections,
field sampling was performed at both the 8-inch and 2-inch vents (as available) at each location to
determine if the vent/area would produce representative LFG. If representative LFG was observed
that met the requirements of Method 25 C (i.e. <5% oxygen or <20% nitrogen by volume), then a
Summa canister sample was obtained. The sampling location map is provided in Attachment A.
Field Sampling Procedures
At each passive vent location on Phases I and II, the passive vent openings were capped with flexible
rubber (fernco) caps tightened to be air-tight with stainless steel band clamps for approximately 24
hours prior to sampling to minimize atmospheric intrusion. For each sample, a 5/16-inch hole was
drilled into the cap to ensure a tight fit with the Teflon tubing for sampling. A photo is provided as
Figure 1.
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
Figure 1 - Capped Phase 1 Vent with Sample Tubing
LFG was sampled in Phase III by utilizing a post-run tubing system inserted through steel probe rods
pushed a minimum of 3 feet into the waste mass. The post-run tubing system is an approved
modification from the stainless-steel probe specified in Method 25C and provides a representative
sample with less potential for short-circuiting or air intrusion. The steel probe was equipped with a
sampling head and an expendable drive point to allow the probe to be driven into the waste. At the
desired depth, the probe rod was withdrawn approximately 6 inches to 1 foot, leaving the expendable
point at depth. Teflon tubing was inserted through the rods and threaded onto the sampling head for
collecting the LFG sample. The tubing was connected to the sampling train at the surface.
At each sampling location, the source of LFG (capped passive vents in Phase I and Phase II, or geo-
probe in Phase III), tubing system, and sampling train were set. The GEM LFG Analyzer was used to
determine methane, carbon dioxide, oxygen, and "balance" gas (primarily nitrogen) content in the LFG.
These parameters were measured and recorded to determine if the LFG being collected would meet
the quality assurance criteria of Method 25C. If the oxygen content was below 5 percent, the sample
was considered representative of LFG and was collected for laboratory analysis. In instances where
atmospheric intrusion was noted; Phase I and II samples were not taken at those vents, or the geo-
probe was pulled out completely and the sampling location was re-pushed in an effort to achieve
quality, representative LFG readings in Phase III.
Methane, oxygen, carbon dioxide and "balance" gas (nitrogen) concentrations were recorded both
prior to and following sample collection at each location. After purging and recording valid LFG flow,
an approximate 1-liter LFG sample was drawn through the flow controller into the canister at a constant
rate of approximately 200 mL/min. The samples were collected over an approximate 5 to 7-minute
duration to insure the collection of the appropriate volume. Additionally, the vacuum pressure readings
on the canister were recorded before and after sample collection. There is a direct correlation between
the volume of sample and decrease in vacuum in the canister. Specifically, each sample volume
decreased the vacuum in the canister by approximately five inches of mercury (HG). Therefore,
approximately three 1-liter (minimum) samples utilize approximately 3 liters of the 6-liter canister; with
the lab-included helium 'pad' in each can utilizing approximately 2 liters, this filling procedure allows
for residual volume and vacuum in the canister (as required by the method). All field measurements
were recorded on the field data forms provided in Attachment B
Following sample collection, the methane, carbon dioxide, oxygen and nitrogen readings were
recorded again in the field to ensure quality representative LFG was sampled throughout the duration
of the sample collection. For Phase III sample locations, the probe rods were withdrawn, and the probe
holes were backfilled with bentonite.
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
Summary of Laboratory Analysis
AAC laboratory performed the Method 25C and Method 3C analyses as required by 40 CFR 62.16718
(Subpart OOO) and 40 CFR 60.35f(a)(3) (Subpart Cf). Method 25C is used to determine the composite
sample NMOC concentration and Method 3C to measure gas composition to determine if significant
air intrusion had occurred during sampling. Table 1 summarizes the laboratory results. Laboratory
analysis reports, including quality control and quality assurance reports, are provided in
Attachment C.
Table 1 - Summary of Laboratory Results
Sample
Canister NMOC as Carbon NMOC as Hexane
Sampling Locations Locations
ID (ppmV) (ppmV)
per Canister
000181 A - C 2 8.4 1.4
000167 VGV-24 - VGV-25 2 7.4 1.2
001480 VGV-13 - VGV-27 2 23 3.8
000102 VGV-35 - VGV-14 - VGV-34 3 Not Used - Outside Acceptable Parameters
000119 PV-3 - PV-2 2 85 14.2
VEN-501 VGV-7 - VGV-4 - VGV32 3 6.7 1.1
000118 PV-2 - PV-1 2 807 134.5
VEN-446 VGV-31 - VGV-30 - VGV-20 3 99 16.4
VEN-122* PV-1 - PV-4* 2 974 162.3
001319* 47 - 49* 2 875 145.8
VEN-308 48 - 47 2 1,140 190
000125 49 - 50 2 108 18
001308 VGV-3 - VGV-21 - VGV-22 3 Not Used - Outside Acceptable Parameters
Weighted Average: 71.9
* Duplicate sample locations - per 40 CFR 62.16718(a)(3) all samples that met the parameters were used in the analysis
The site-specific NMOC weighted average of 71.9 ppmv (as hexane) was calculated by mathematically
determining the weighted average (based on number of sample locations per canister) of the
laboratory results of 24 sampling locations at the site. Out of the 30 samples collected, 6 samples (2
canisters) were discarded due to being outside acceptable parameters (<5% oxygen or <20% nitrogen
by volume).
Tier 2 NMOC Emission Estimate
In order to estimate the landfill NMOC emission rate, the annual waste receipts and the weighted
average site-specific NMOC concentration calculated from the Tier 2 sampling results are input in the
EPA Landfill Gas Emission Model (LandGEM). This model estimates emissions using the equation
shown in 40 CFR 62.16718(a)(1) (Subpart OOO) and 40 CFR 60.35(f)(a)(1) (Subpart Cf).
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
Waste Disposal Rates
Annual waste disposal rates from 1972 through 2016 were obtained from the LCCSWMF 2021
Greenhouse Gas Summary Report and are consistent with the previous Tier 2 NMOC analysis
conducted in 2012 by HDR. The County reports that the LCCSWMF stopped accepting waste after
2016.
Model Parameters
The NSPS default values for the methane generation potential (L = 170 m3/Mg), methane generation
o
rate constant for wet climates (k = 0.05 yr-1), and methane concentration of 50 percent were used in
the model. The site specific NMOC weighted average of 71.9 ppmv (as hexane) was used based on
the sampling and analysis results. Note that this value is consistent with previous sampling at the site
(2012 value 53.45 ppmv hexane).
NMOC Emission Estimate Model Results
Based on the EPA LandGEM model results using site-specific information and NSPS default
parameters, the estimated annual NMOC emissions for 2022 is 2.250 megagrams (Mg). A copy of the
EPA LandGEM model report is provided in Attachment D.
The model output NMOC generation rates for the next 5 years are summarized in Table 2 and is
declining as shown. Projected waste disposal rates for years 2022 through 2027 are shown as zero
due to the closure status of the LCCSWMF Phase I and Phase II landfills and the planned closure of
the Phase III landfill. Specifically, Phase III closure construction is scheduled to start by the end of
2022 with final completion scheduled for April 2023 - per recent FDEP Notice of Permit dated October
22, 2021 (Permit Number 0125106-035-SF-01).
Table 2 - EPA LandGEM Model Output
Year Projected MSW Disposal Rate (tons/yr) NMOC Generation Rate (Mg/yr)
2022 0 2.250
2023 0 2.140
2024 0 2.036
2025 0 1.936
2026 0 1.842
2027 0 1.752
Conclusion and Recommendations
Based on the EPA LandGEM model results using site-specific information, the 2022 value for annual
NMOC emissions is 2.250 Mg. This NMOC emissions estimate is less than the 34 Mg annual threshold
for compliance with LFG collection and control portions of the applicable rules. Therefore, an LFG
collection and control system is not required by NSPS/EG at this time. Since the LCCSWMF does not
expect to receive any more waste, the landfill is never expected to reach these regulatory threshold
emission rates.
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
NSPS requires the County to perform Tier 2 NMOC sampling and reporting within 5 years of the
previous report (in lieu of annual updates) as long as annual waste acceptance rates are at, or below,
those utilized in this Report. The County does not expect to receive any more waste, as Phase I and
Phase II are closed landfills and Phase III is undergoing closure. Therefore, the LCCSWMF anticipates
that it will not be subject to further Tier 1 or Tier 2 NMOC Emission Rate reporting under NSPS
Subparts Cf or Subpart OOO for these permitted waste cells.
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Tier 2 NMOC Emission Rate Report
Lake County Central Solid Waste Management Facility
Appendix A - Landfill Gas Sampling
Locations
8

PV-15 PV-14
PV-13
PV-16
S43
PV-4
PV-12
PV-1
PV-17
S44
PV-11
PHASE II
S45
LC-4 LC-3 PV-18 PV-2 PV-10
S50
PV-3
S49 PV-5 PV-9
S46
PHASE III
S48 PV-6 PV-8
PV-7
S47 LC-2
LC-1
A
VGV15
VGV25
VGV24
VGV23
VGV1 VGV26
VGV14
VGV32
VGV22 PHASE I
VGV2 VGV31 VGV27 VGV13
VGV34
C
VGV35
VGV21
VGV3 VGV30
VGV29 VGV10
VGV28 VGV11
VGV20
VGV19
VGV18
VGV4 VGV9
VGV17
VGV5 VGV8
VGV6
VGV7
LEGEND PROJECT TITLE LAKE COUNTY CENTRAL (ASTATULA) LANDFILL TIER 2 TESTING PROJECT NUMBER REFERENCE SHEET
VGV14 EXISTING PHASE I PASSIVE VENT LAKE COUNTY, FLORIDA 10343382
PV-12 EXISTING PHASE II PASSIVE VENT SHEET TITLE PROJECT MANAGER REFERENCE DOCUMENT
TIER 2 SAMPLE LOCATION MAP J. MILLER, P.E.
LC-1 EXISTING PHASE III LEACHATE CLEANOUT
DATE EXHIBIT NUMBER
400 0 400 S1 PROPOSED SAMPLING LOCATION AUGUST 2022 1
APPROXIMATE HECTARE DELINEATION
SCALE IN FEET
APPROXIMATE WASTE LIMITS