Exhibit_G_-_27th_Ave_Non_Title_V_2025_Permit_Renewal_Application.pdf

27th Avenue Solid Waste Municipal Landfill Permit Renewal of Permit No. P0007332

Submitted to:

Maricopa County Air Quality Department 3800 N. Central Phoenix, AZ 85004

(602) 506-6010

Submitted by:

City of Phoenix Public Works Department 3060 South 27th Avenue Phoenix, Arizona 85009

(602) 534-3333

Prepared by:

Tetra Tech BAS, Inc.

22601 N. 19th Avenue, Suite 225 Phoenix, Arizona 85027

(602) 267-0336

September 19, 2025

Non-Title V Air Quality Operating Permit Application 27th Avenue Solid Waste Municipal Landfill

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TABLE OF CONTENTS

SECTION DESCRIPTION PAGE

1.0 INTRODUCTION

2.0 OPERATING PERMIT HISTORY

3.0 PROCESS DESCRIPTIONS AND PROCESS FLOW DIAGRAMS

3.1 Landfill Waste Operations

3.2 Formation of Landfill Gas

3.3 Formation of Landfill Condensate

3.4 Landfill Flare Station Operations

3.5 Leachate Collection System

3.6 Process Flow Diagrams

4.0 ACTUAL & ESTIMATED POTENTIAL TO EMIT (PTE) EMISSIONS

5.0 EMISSION RELATED INFORMATION

5.1 Non-Fugitive Emission Sources

5.1.1 Landfill Gas Enclosed Flares

5.1.2 Non-Fugitive Exempt Sources

5.2 Fugitive Emission Sources

6.0 CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS

7.0 DUST CONTROL

LIST OF TABLES

Table 2-1 Municipal Solid Waste Landfill Permit History

Table 3-1 Existing 27th Avenue Landfill Enclosed Flare

Table 3-2 Existing Enclosed Flare Exhaust Stack Data

Table 4-1 Projected Actual Air Emission Limits

Table 4-2 Facility-Wide Potential to Emit Estimate

Table 4-3 Existing and Proposed Emission Limits

LIST OF FIGURES

Figure 2-1: 27th Avenue Landfill Site Plan

Figure 3-1: 27th Avenue Landfill Process Flow Diagram

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LIST OF ATTACHMENTS

Attachment A: 27th Avenue Landfill Operation & Maintenance Plan Attachment B: 27th Avenue Landfill Dust Control Plan Attachment C: Potential To Emit (PTE) Emissions Summary and Calculations Attachment D: Historical LandGEM Modeling Results Attachment E: MCAQD Review of 2023 Enclosed Flare Source Testing & Summary Sheets Attachment F: Current Non-Title V Air Quality Operating Permit Attachment G: MCAQD Non-Title V Permit Application Forms

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1.0 INTRODUCTION

The City of Phoenix (COP) owns and operates the 27th Avenue Municipal Solid Waste Landfill (27th

Avenue Landfill) in Maricopa County within COP city limits. The 27th Avenue Landfill is located at 2800

South 27th Avenue south of Lower Buckeye Road and between 27th Avenue and 35th Avenue in Phoenix, Arizona. The closed landfill is approximately 147 acres. The 27th Avenue Landfill contains only municipal solid waste including residential and commercial wastes, and construction debris.

The 27th Avenue Landfill began accepting waste in 1978 and ceased municipal solid waste landfilling operations in 1995. The 27th Avenue Landfill contains a total of about 10.8 million tons of municipal solid waste and soil cover material. The 27th Avenue Landfill was not permitted for disposal of any hazardous waste or asbestos-containing materials. The COP operates a transfer station south of the landfill under a separate operating permit.

The 27th Avenue Landfill has an approved dust control plan in place which describes various measures to control particulate matter, with a diameter of 10 micrometers, (PM10) emissions. The City presently operates under the Non-Title V Air Quality Operating Permit No. P0007332 (Appendix E). Permit

P0007332 establishes compliance conditions for the landfill maintenance, including operation of the landfill gas flare and fugitive dust emission sources.

During the last permitting period, in 2018, the 65.52 MMBtu/hr enclosed ground flare was replaced with a smaller capacity flare rated at 18 MMBtu/hr and a maximum flow 1,500 scfm. The 18MMBTU/hr flare was source tested in 2018 and again in 2023. The emission calculations are based on the 2023 source test. Pertinent data from the source test is also included in Appendix B.

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2.0 OPERATING PERMIT HISTORY

The 27th Avenue Landfill, was subject to the New Source Performance Standards (NSPS) for Municipal

Solid Waste Landfills (Subpart WWW) and was permitted initially as a Title V source in 2003. In 2016, when the non-methane organic carbon (NMOC) emissions declined below the 50 Mg/yr threshold, the

COP requested the closure of the Title V permit and the issuance of a Non-Title V permit. Table 2-1 below summarizes the permit history for the 27th Avenue Landfill.

Table 2-1: 27th Avenue Municipal Solid Waste Landfill Permit History Permit Number Issuance Date Purpose of Issuance V98-002 May 29, 2003 Initial Title V Operating Permit V98-002 December 29, 2010 Title V Operating Permit Renewal 150058 April 6, 2016 Initial Non-Title V Operating Permit 150058 August 11, 2020 Non-Title V Operating Permit Renewal Application P0007332 May 1, 2021 Non-Title V Permit Renewal Issued

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Figure 2-1: 27th Avenue Landfill Site Plan

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3.0 PROCESS DESCRIPTIONS AND PROCESS FLOW DIAGRAMS

3.1 Landfill Waste Operations

The City of Phoenix (COP) owns and operates the 27th Avenue Municipal Solid Waste Landfill, located at

2800 South 27th Avenue in Phoenix, Arizona, south of Lower Buckeye Road between 27th Avenue and 35th

Avenue. The site encompasses approximately 1,500 acres, with 147 acres currently stabilized or vegetated. The landfill began accepting municipal solid waste in 1978 and ceased landfilling operations in

1995. Waste disposal at the site followed an area fill method, where residential, commercial, and construction debris were spread in thin layers and compacted to maximize density. Cover soil excavated on site was used for daily and intermediate cover, as well as for berm construction, roadways, and final cover features. No hazardous or radioactive wastes, including asbestos-containing materials, were accepted at the facility.

Upon closure in 1995, all active operations, such as recycling and grinding, were decommissioned and all related equipment, including a parts washer that used degreasing solvent, was removed. The site now contains approximately 10.8 million tons of waste and cover material. Final soil cover was placed to reduce infiltration and emissions, and the area was stabilized with hydroseeding to control erosion. Perimeter fencing and signage were installed to secure the site and prevent unauthorized access.

3.2 Formation of Landfill Gas

The landfilled waste material decomposes through organic processes. This decomposition is aerobic until the oxygen is nearly depleted within the waste at which time anaerobic decomposition begins. The landfill gas (LFG) generated in the decomposition process is primarily composed of methane and carbon dioxide.

Small amounts of other compounds are also present in the gas, which are mostly NMOCs, including VOCs and HAPS, and leachate (water which comes into contact with the waste mass). To limit the emission of the gaseous compounds through the landfill surface and into the atmosphere, a gas collection and control system (GCCS) was installed.

The GCCS consists of vertical wells placed in the refuse prism and connected to a vacuum source by high-density polyethylene (HDPE) and Polyvinyl chloride (PVC) headers. The LFG is removed under vacuum from the refuse prism as it is produced. The GCCS is designed to prevent lateral and vertical migration of landfill gas. The extracted LFG is then delivered to a high temperature enclosed flare at the flare station where the LFG is combusted under controlled conditions into carbon dioxide and water vapor. During this

Tetra Tech BAS September 2025 5 combustion process, various criteria air pollutants (NOx, SOx, and CO) are emitted. Also emitted through the extraction and treatment process is particulate matter (PM) and pseudo-particulate matter

(condensable salts). Source emission testing is performed at five-year intervals to verify the destruction efficiency of the GCCS.

3.3 Formation of Landfill Condensate

The LFG generated is saturated with water vapor. As the LFG moves through the conveyance piping to the flare stations it cools, the water vapor condenses and becomes condensate. The condensate contains organic compounds (NMOC, VOC, and HAPs,) that were extracted from the waste mass in the vapor phase.

The condensate is collected in sumps located at engineered low points in the header system and pumped to the flare station for storage and periodic destruction.

3.4 Landfill Flare Station Operations

There is currently one (1) Flare Station at the 27th Avenue Landfill located on the southeast side of the 27th

Avenue Landfill. The flare station site currently includes the operation of one (1) Perennial Energy Inc.

(PEI) LFG flare with the specification listed in Tables 3-1 and 3-2 below. This enclosed flare serves as the primary control device for LFG destruction with a heat input capacity of 18 MMBtu/hr and a maximum flow 1,500 scfm.

Table 3-1: Existing 27th Avenue Landfill Perennial Energy, Inc. Enclosed Flare Criteria Flare Station

Flare Designation S-1 Enclosed Flare Minimum Operating Setpoint in Flare Combustion Zone (˚F) 1,400

Maximum Inlet Landfill Gas Flow rate, scfm 1,500 Maximum Heat Rate, MMBtu/hour 18

Table 3-2: Existing Enclosed Flares Exhaust Stack Data

Flare Identification Stack

ID

Vertical Stack Height (ft.)

Stack Inside Diameter (inches)

Exhaust Gas Temperature (˚F)

Exhaust Gas Flow Rate (dscfm)

Flare Station 1 Flare 1 (S-1) 1 30 76 1,508 6,074

Notes:

(1) The listed exhaust gas temperatures (˚F) and flow rates are the average of three (3) exhaust gas temperature and flow readings from the S-1 June 2023 source test.

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3.5 Leachate Collection System

A leachate collection and removal system (LCRS) is installed in the lined portions of the 27th Avenue

Landfill to manage and remove leachate generated by decomposing waste. The system includes a low-permeability liner, a sump at the base of the landfill cell, perforated collection piping, a riser pipe, and a submersible pump to transfer leachate from the sump to an aboveground storage tank for proper management. Only some portions of the landfill are lined and equipped with leachate collection infrastructure, as the site began operations prior to the implementation and requirements of Subtitle D

(40 CFR Part 258). However, where liners and sumps are present, collected leachate is pumped to a

4,000-gallon aboveground steel storage tank located within the gas flare compound. Vapors from this tank are routed through a carbon adsorption canister to control emissions. The leachate system is operated and maintained in accordance with the site’s Operation and Maintenance (O&M) Plan and permit conditions. Maintenance activities include routine pump inspections, level monitoring, carbon canister replacement, and off-site disposal of accumulated leachate by licensed haulers.

3.6 Alternative Operational Scenarios

3.6.1 Intermittent Wellfield Component Operation

COP respectfully requests regulatory approval to operate certain LFG wells on an intermittent basis or to close them as necessary, based on site-specific gas constituent conditions. As the landfill continues to mature, LFG generation has naturally declined, making consistent operation of older wells increasingly challenging. Aging collection system infrastructure, combined with settlement across waste cells, has contributed to variable performance and increased susceptibility to air intrusion. This has resulted in elevated oxygen and balance gases entering the system, which dilutes the collected LFG and adversely affects flare operation and overall system efficiency.

Continued operation of such wells under declining gas conditions often exacerbates oxygen intrusion, reduces gas quality, and increases the potential for surface emissions. Conversely, strategic intermittent operation or closure of underperforming wells allows operators to focus collection efforts on stronger wells, optimize gas quality for control, and maintain stable flare performance. The facility is committed to maintaining compliance with all state landfill gas regulations and will continue to implement best practices, including routine field balancing, targeted well rehabilitation, and replacement of aging components. Approval of this request will allow the facility to manage the collection system in a manner

Tetra Tech BAS September 2025 7 that reflects site-specific conditions while ensuring continued environmental protection and regulatory compliance.

3.6.2 Intermittent Flare Operation

In addition to the intermittent operation of some of the LFG wells COP requests that the current permit be updated to allow for intermittent operation of the enclosed flare as needed to maintain emission and migration control based on the LFG generation. Since the LFG generation will continue to decline at the

27th Avenue Landfill due to the aging of the waste mass and reduction in organic matter in the waste prism, an overall reduction both the recorded methane concentrations and extraction flow rates of the generated LFG will occur. Consequently, the overall heat input rate of the LFG will also decline, which will impact the existing flare’s ability to operate continuously regardless of the components that may be operated intermittently or closed. The ability to cycle the flare on and off as needed, while maintaining compliance with monitoring and performance requirements, will allow COP the flexibility to manage the collection at the site in a more efficient and environmentally appropriate way during the post-closure phase of the landfill.

3.7 Process Flow Diagrams

Process flow diagrams for 27th Avenue Landfill operations representative of both fugitive emission sources and non-fugitive emission sources are illustrated in Figure 3-1 on the following page.

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Figure 3-1: 27th Avenue Landfill Process Flow Diagram

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4.0 ACTUAL & ESTIMATED POTENTIAL TO EMIT (PTE) EMISSIONS

This Non-Title V renewal application includes Projected Actual Air Emissions. The basis for these calculations is the actual measured flows and the emission factors determined during the June 2023

Source Test for the S-1 Flare. Since the flow and gas quality are in decline at 27th Avenue Landfill this is a conservative approach. Table 3-1 below includes the projected actual emissions. Details of the emission calculations are included as part of the Non-Title V Application in Attachment C.

Table 4-1: Projected Actual Air Emission Limits

POINT SOURCE ESTIMATED POTENTIAL TO EMIT TOTALS, tpy

Emission Unit I.D. Emission Unit Description NMOC VOC HAPs CO NOX SOX PM PM10 PM2.5

Landfill Site Point Source Emission (1): 0.48 0.04 0.72 0.84 0.47 1.06 0.73 0.73 0.73

S-1 Flare Station 1, Flare 1 0.48 0.04 0.72 0.84 0.47 1.06 0.73 0.73 0.73

NOTES: (1) Used for Source Classification (e.g., Non-Categorical Source whereby fugitive emissions are not to be included in the source classification emissions total).

A historical LandGEM model has been included to estimate landfill gas (LFG) generation, incorporating historical waste inflow data at the 27th Avenue Landfill. Fugitive hazardous air pollutant (HAP) emissions are based on constituent values from EPA’s AP-42 emission factors. Table 4-2 summarizes the estimated potential-to-emit (PTE) in tons per year for regulated pollutants, while Table 4-3 presents both existing and proposed emission limits. All values shown in Table 4-2 represent “worst-case” maximum PTE over the five-year term of the Non-Title V Operating Permit, extending through 2030. The worst-case flow rate is based on the flare operating at full capacity continuously (24 hours per day) for one year. Emission factors were derived from the 2023 source test and approved by the Maricopa County Air Quality

Department (MCAQD). Details of the PTE calculations are provided in Attachment C, and the results of the historical LandGEM modeling are included in Attachment D.

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Table 4-2: Facility-Wide Potential to Emit Estimate

FACILITY-WIDE POTENTIAL-TO-EMIT (PTE) TOTALS, tpy

Emission Unit I.D. Emission Unit Description NMOC VOC HAPs CO NOX SOX PM PM10 PM2.5

Landfill Site Maximum Point Source Emissions:(2)

S-1 Flare Station 1, Flare 1 1.05 0.09 3.72 1.86 1.04 2.33 1.62 1.62 1.62

Non-Fugitive PTE Totals 1.05 0.09 3.72 1.86 1.04 2.33 1.62 1.62 1.62

Landfill Surface Fugitive Emissions:

Unpaved Roadway Emissions − − − − − − 150 40 4

Landfill Gas Fugitive Emission 6.84 4.40 3.22 − − − − − −

Fugitive PTE Totals 6.84 4.40 3.22 0.00 0.00 0.00 150 40 4

NOTES: (1) S-1 is rated to operate at a maximum of 18 MMBtu/hr and represent the greatest potential to emit in any operating scenario.

Table 4-3: Existing and Proposed Facility-Wide Emission Limitations

Regulated Pollutant

Current Rolling Twelve Month Emission Limits

Proposed Rolling Twelve Month Emission Limits

Volatile Organic Compounds (VOC) 7.36 tons 7.36 tons

Carbon Monoxide (CO) 6.74 tons 6.74 tons

Nitrogen Oxides (NOx) 6.60 tons 6.60 tons

Hydrogen Sulfide (H2S) 2.11 tons 2.11 tons

Total or any Single Hazardous Air Pollutant (HAP) 5.00 tons 5.00 tons

The PTE stationary source emission totals shown in Table 3-2 are well below the currently permitted emission limits shown in Table 3-3.

5.0 EMISSION RELATED INFORMATION

Total emissions and supporting calculations showing emissions from each source are presented in

Attachment C. LFG that cannot reasonably be collected by the landfill gas collection and control system

(GCCS) is treated as fugitive emissions and is not included in source-wide potential to emit (PTE). The 27th

Avenue Landfill GCCS collection efficiency assumed to be 75% (AP42 default value) with the remaining

25% of LFG generated by the landfill considered to be fugitive.

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5.1 Non-Fugitive Emission Sources

5.1.1 Landfill Gas Enclosed Flares

The 27th Avenue Landfill currently has one (1) flare on the property which is utilized for combustion of the

LFG collected in the existing gas collection system. The flare is located at the flare station on the southeast side of the landfill. Combustion of LFG in the enclosed flare results in criteria air pollutant emissions and

HAP emissions. Table 3-2 provides existing enclosed flare exhaust stack data. The VOC and HAP emission rates and destruction efficiencies used in the emission calculations were determined during the June 2023 performance source test that was reviewed and approved by the MCAQD. The SO2 emissions from the flare were calculated assuming that the total reduced sulfur (TRS) routed through the flare is converted entirely to SO2. The MCAQD approval letter of the 2023 source test emission factors is provided in

Attachment E.

5.1.2 Non-Fugitive Exempt Sources

The collected condensate contains organic components (NMOC, VOC, and HAPs). To prevent the buildup of desorbed gases in the flare station storage tank, an exhaust vent system was designed such that any air leaving the tank is passed through a 55-gallon granulated activated carbon unit. This canister is in place to control odors and VOC emissions that may desorb from the condensate and accumulate in the headspace of the tank. This tank is monitored on a regular basis using a photoionization detector (PID) and/or flame ionization detector (FID) organic gas-analyzing instrument to determine if gas breakthrough has occurred.

5.2 Fugitive Emission Sources

The 27th Avenue Landfill generates fugitive PM emissions from light duty vehicle travel on unpaved roadways and inactive areas. The inactive areas are vegetated and stabilized for dust mitigation while unpaved roadways incorporate asphalt millings dust suppression mitigation measures.

In addition to particulate fugitive emissions, LFG not captured by the LFG collection system (modeled as

25% of the LFG generated,) is emitted as fugitive emissions. These emissions contain NMOCs, VOCs, and

HAPs, are generated by the microbial degradation of buried refuse. The modeling of landfill gas generation was performed using EPA’s LandGEM – Landfill Gas Emission Model, version 3.02. The LandGEM results are based on parameters for the methane generation rate (k), potential methane generation capacity (Lo), NMOC concentration, and methane content. Each of these parameters affects the outcome of the model.

Tetra Tech BAS September 2025 12

The LandGEM can be run with default EPA values or can be modified to fit the specific landfill. For the purposes of the application, the LandGEM model was modified to better fit actual site parameters for 27th

Avenue Landfill. For the methane generation rate (k), a user specified value of 0.0045 was used as well as the average NMOC rate from the most recent source test. The potential methane capacity (Lo) was set for the default value of 100 and the methane concentration was set to 50 percent (50%) to normalize the values generated. These parameter values were selected based on the fact that the 27th Avenue Landfill has a GCCS that fully covers the landfill waste footprint (where waste was deposited) and has had no issues with surface emissions for several years. Based on this information and the current/historical flow rates recorded at the flare, the LandGEM model with the user input values has produced results closer to the conditions currently being observed at the landfill. Results of the modeling are included in Attachment

D.

6.0 CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS

The 27th Avenue Landfill was subject to Title V regulations as part of conformance to the Emission

Guidelines (EG) for Municipal Solid Waste (MSW) Landfills, promulgated under 40 Code of Federal

Regulations (CFR) Part 60, Subparts Cc and WWW, and codified under Maricopa County Rule 321.

Maricopa County Rule 321 adopted and incorporated 40 CFR 60, Subpart WWW by reference. As of

September 2021, 40 Code of Federal Regulations (CFR) Part 60, Subparts Cc and WWW have been replaced in practice by Subparts Cf and OOO. As such, Maricopa County Rule 321 was revised in September

2022 to reflect the new federal regulations. As the site is no longer subject to either federal regulation, it is still subject to the requirements of Maricopa County Air Pollution Control Regulations.

The facility is classified as a minor stationary source, for Prevention of Significant Deterioration (PSD) as the facility has a potential to emit for each regulated pollutant that is less than the applicability threshold for PSD major source status. As the facility is not one of the listed 28 source categories listed in 40 CFR

52.21(b)(1)(i)(c)(iii), fugitive emissions are not considered for PSD purposes. The facility will remain a minor source after issuance of the renewed Non-Title V permit.

7.0 DUST CONTROL

27th Avenue Landfill complies with an approved Dust Control Plan under the existing Non-Title V Permit.

The current Dust Control Plan is submitted as required with this application. Note that all significant

Tetra Tech BAS September 2025 13 anthropogenic dust-emitting operations have ceased following the completion of final cover closure construction activities at the 27th Avenue Landfill. Infrequent vehicle traffic related to GCCS operation and maintenance activities are an insignificant source of fugitive dust emissions. Control of dust emissions due to wind erosion and other activities is accomplished by the following actions:

• Extensive hydro-seeding was performed, as part of the final cover construction operation, to stabilize the soil and minimize erosion and offsite discharge of soils during adverse weather events.

• Perimeter security fencing and appropriate signage were installed to limit vehicle traffic over landfill surfaces by preventing public access to (and discourage trespassing onto) the 27th Avenue Landfill.

• Asphalt millings are installed on major perimeter access roads.

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ATTACHMENT A: 27TH AVENUE LANDFILL

OPERATION & MAINTENANCE PLAN

27TH AVENUE LANDFILL

Operations & Maintenance Plan Flare Station

July 2021 Form updates September 2025

Public Works Department

27th Avenue Landfill Flare Operations and Maintenance Manual

27th Avenue Landfill, O&M Plan

TABLE OF CONTENTS

GENERAL INFORMATION

BUSINESS NAME:

BUSINESS ADDRESS:

MARICOPA COUNTY AIR PERMIT NUMBER:

DATE OF PREPARATION/REVISION:

OVERALL FACILITY OPERATIONS:

PROCESS DUCTED TO CONTROL DEVICE:

CONTROL DEVICES COVERED BY THE PLAN:

OPERATION PLAN

OPERATING PARAMETERS TO BE MONITORED:

RECORDING MEASUREMENTS AND TYPE OF INSTRUMENTATION:

MAINTENANCE PLAN

OTHER INFORMATION

APPENDICES

Appendix A Monthly Flare Operations Log Appendix B Maintenance Log Appendix C Monthly Compressor Maintenance Form Appendix D 27th Avenue Landfill Shutdown Log Appendix E Equipment Data Sheet for PEI Flare

27th Avenue Landfill, O&M Plan 1

GENERAL INFORMATION

Business Name:

City of Phoenix - Public Works Department

Business Address:

27th Avenue Landfill 2800 S. 27th Avenue Phoenix, Arizona 85009

Maricopa County Air Permit Number:

Non-Title: P0007332 (Legacy Permit 150058)

Date of Preparation/Revision:

June 29, 2021

Overall Facility Operations:

The 27th Avenue Landfill is a closed municipal landfill. Currently, operations at the facility consist of operation and maintenance of the landfill gas collection system, blower & blower motors, compressor, and landfill gas flare.

Process Ducted to Control Device:

The landfill gas is extracted from the landfill via vertical collection wells. It is then conveyed from the wells to blowers, which are connected to a Perennial Energy flare rated at a maximum of 18 MMBtu/hr (control device) that burns the landfill gas before emitting combustion products to the atmosphere. The landfill gas at the flare ranges from approximately 35% to 38% methane with the majority of the gas consisting of carbon dioxide, oxygen and nitrogen. A small fraction (less than 1%) of the landfill gas is composed of trace elements such as hydrogen sulfide or volatile organic compounds. A carbon canister is installed on the condensate/leachate tank passive vent so as to mitigate VOC emissions.

Control Devices Covered by the Plan:

Device Description Date Installed

Number of Units

Manufacturer Model Rated Capacity

Flare VOC Destruction

2018 1 PEI Enclosed Flare

1500 cfm

Condensate/ Leachate

Tank Carbon Canister

NMOC/VOC

Adsorption

1996 1 US Filter Vent- Scrub, SN #005670

55 gallon

27th Avenue Landfill, O&M Plan 2

OPERATION PLAN

Operating Parameters to be Monitored:

Parameter Units Lower Limit Upper Limit Frequency Flare Flow Rate2 Cubic feet per minute (cfm) 200 1500 Continuous1 /

Monthly Flare Temperature3 Degrees

Fahrenheit (oF) 1400 2000 Continuous1 /

Monthly Startup, Shutdown, &

Malfunction Log Hours per event NA NA Per Event

1"Continuous" measurements are automatically recorded on digital chart recorder. "Monthly" measurements are recorded manually on “routine” data forms.

2Kurz Mass Flow Meter – Flow meter is calibrated annually.

3The set point operating temperature of the flare is set to 1,475 deg F as determined during the April 18, 2018 performance test. NOTE: this temperature may fluctuate about 50 oF.

Recording Measurements and Type of Instrumentation:

Parameter Method Instrument Lower Limit

Upper Limit

Flare Flow Rate

(continuous)

Digital Data Recorder

Kurz Meter/C-More Digital Recording Device

200 cfm >1500 cfm

Flare Flow Rate

(monthly)

Manual Monthly Log / Digital Storage

Kurz Meter/C-More Digital Recording Device

200 cfm >1500 cfm

Flare Temperature (continuous)

Digital Data Recorder

Type K Thermocouple/C- More Digital Recording

Device

0oF 2000oF

Flare Temperature

(monthly)

Manual Monthly Log / Digital Storage

Type K Thermocouple/C- More Digital Recording

Device

0oF 2000oF

Appendix A to this O&M Plan contains the Monthly Operations Log. The C-More digital recording device (with memory cards) and completed daily and monthly logs will be maintained either on-site or filed at the main file location (currently the 27th Avenue Waste Management Facility). Operations records will be maintained for five (5) years.

The flare station Preventative Maintenance checklist is included in Appendix B. The flare station Maintenance Log is included in Appendix C. A Monthly Shutdown Log for recording shutdowns is included as Appendix D.

27th Avenue Landfill, O&M Plan 3

MAINTENANCE PLAN

Maintenance procedures are performed on a routine basis to ensure the equipment remains in good operating condition. Maintenance will be performed on the devices listed under the General Information section of this O&M Plan.

Monthly monitoring will include inspection of each piece of equipment for breaks, leaks or loose wires. This general inspection will be completed during the operational site visit. Monthly maintenance monitoring will also include checking the pilot fuel level, the main valve operation, the louver motor operation, the air compressor operation and the knockout vessel condensate level. Should the inspector note a problem with the equipment during monitoring, the problem and the corrective actions to mitigate the problem will be noted on the Maintenance Log (Appendix B). The knockout vessel and/or air compressor tank will be drained and the pilot fuel container filled as necessary to ensure proper operation of the units. Compressor inspection will be conducted monthly and documented on the Monthly Compressor Maintenance Form (Appendix C).

Quarterly maintenance monitoring will include checking the safety equipment on the devices, the louver linkages for looseness and/or binding, the flame arrestor, monitoring of the condensate storage tank (CST) carbon vessel with an IRwin (inferred detection) device, and the knockout filter. Should the inspector note a problem with the equipment during monitoring, the problem and the corrective actions to mitigate the problem will be noted on the Maintenance Log (Appendix B). Knockout filters will be replaced or cleaned as necessary to insure proper operation of the unit.

Annual inspection of the air compressor air filter, airline filters, control panel, blower motor lubrication, main inlet valve and all thermocouples will be conducted. The blower motors will be lubricated and air compressor filters will be replaced or cleaned as necessary to insure proper operation of the units. Should the inspector note a problem with the equipment during monitoring, the problem and the corrective actions to mitigate the problem will be noted on the Maintenance Log (Appendix B). Annual maintenance of the compressor is conducted per manufacturer recommendations.

All routine maintenance inspections as well as corrective actions to fix problems noting during inspections will be recorded on the form provided in Appendix B to this O&M Plan. The completed forms will be maintained either on-site or at the main file location (currently the 27th Avenue Waste Management Facility) for five (5) years.

OTHER INFORMATION

A copy of the manufacturer O&M Plan for the blowers and flare can be found at the main file location.

27thAveLF OM Plan May15

APPENDIX A

MONTHLY FLARE OPERATIONS LOG

27TH AVENUE LANDFILL FLARE STATION MONITORING FORM

FLARE SYSTEM: BAS PROJECT NO.:

WEATHER CONDITIONS: DATE:

AMBIENT AIR: TIME:

BAROMETRIC PRESSURE: TECHNICIAN:

INSTRUMENT SERIAL NO.:

BLOWER SYSTEM Interior Blr 1

Interior Blr 2

Perimeter Blr 301

Perimeter Blr 302 FIELD INLET SYSTEM

Operating Blower Field Inlet Methane Concentration (% VOL)

Blower Running Hours Field Inlet Carbon Dioxide Concentration (% VOL)

Blower Current (in Hz) Field Inlet Oxygen Concentration (% VOL)

Blower Inlet Vacuum (INCHES W.C.) Field Inlet Balance Concentration (% VOL)

Blower Discharge Pressure(INCHES W.C.) Field Inlet LEL Concentration (% VOL)

Blower Differential Pressure (INCHES W.C.) Field Inlet Gas Temp. (°F)

Blower/Motor Lubrication (Y/N or NS) Field Inlet Vacuum (INCHES W.C.)

Date of Last Blower/Motor Lube Gas Velocity (FPM)

Hours of Last Blower/Motor Lube Field Inlet Pipe Average I.D (INCHES) - 10-inch HDPE SDR-17 9.410

Rupture Disk (operational, OP - nonoperational, NONOP)

FLARE SYSTEM CONDENSATE MANAGEMENT SYSTEM

Flare Flow Rate at Yokogawa Chart Recorder* Demister Liquid Level (INCHES)

Interior Flare Temperature at Kurz Meter Demister Inlet Static Pressure (INCHES W.C.)

Interior Flare Flow Rate at Kurz Meter Demister Discharge Static Pressure (INCHES W.C.)

Perimeter Flare Temperature at Kurz Meter Demister Differential Pressure (INCHES W.C.)

Perimeter Flare Flow Rate at Kurz Meter Condensate Holding Tank Level (INCHES)

Flare Inlet Pressure (INCHES W.C.)*

Flare Inlet Gas Temp. (°F)*

Annubar Differential Pressure (INCHES W.C.)

Calculated Flowrate from Annubar Diffrential Pressure (SCFM)

Panel/Calculated Flowrate Percent Difference (%) COMPRESSOR SYSTEM F.A. Inlet Static Pressure (INCHES W.C.)** Compressor Oil Level (OK or NS)

F.A. Outlet Static Pressure (INCHES W.C.)** Compressor Air Filter (OK or NS)

F.A. Differential Pressure (INCHES W.C.)** 0.00 0.00 Auto Drain (OK or NS)

Operating Thermocouple (1-Bot, 2-Mid or 3-Top) 2 2 2 2 Oil Water Separator (OK or NS)

Flare Operating Temperature (°F) - Taken at touchscreen

Flare Operating Temperature Setpoint (°F) 1475 1475 1475 1475

High Temp Shutdown Set Point ( oF) 1800 1800 1800 1800

Low Temp Shut Down Set Point (oF) 1400 1400 1400 1400 CARBON CANISTER at FLARE (QUARTERLY) Flare Inlet Valve Pressure (PSI)

Louver Motor Linkage Condition (OK or NS)

Damper Lever Condition (OK or NS)

IGNITION SYSTEM ELECTRICAL BREAKERS

Propane Tank Level (Left - % FULL) Tripped Breakers Upon Arrival (Described below)

Propane Tank Level (Right - % FULL) 1)

2)

CONTROL PANEL

Autodialer Status (A-Armed or D-Disarmed) VALVE POSITION Alarms Activated Upon Arrival (Alarms described below) Field Inlet Valve (% CLOSED)

1) Blower Interior Blr-1 Inlet Valve (% CLOSED)

2) Blower Interior Blr-2 Inlet Valve (% CLOSED)

Blower Perimeter-301 Inlet Valve (% CLOSED)

Blower Perimeter-302 Inlet Valve (% CLOSED)

LEGEND: OR = OVER RANGE ND = NOT DETECTED NS = NEEDS SERVICING NM = NOT MONITORED N/A = NOT APPLICABLE * TOTAL NON-METHANE ORGANIC COMPOUNDS

COMMENTS:

Reviewed: Date:

Perennial Energy (18 MMBtu Flare) 2016-0135-300 oF Local

Monitored at Discharge (Toxic Vapor Analyzer: Organic PPMV)

Date Last Monitored

"Hg Local

27thAveLF OM Plan May15

APPENDIX B

MAINTENANCE LOG

Item: Date:

Technician

Performing

Inspection:

Functioning

Properly

(Y/N)

Comments:

Inspect all pneumatic pumps

Inspect control panel functions

Inspect autodialer operation

Inspect flare data recorder operation and collect data

Inspect blower operation

Inspect air compressor operation

Inspect flare burner head

Overall Inspection from field inlet to flare.

Additional Items

Description: Date(s): Work Order # Complete

(Y/N) Comments:

27th Ave Landfill Maintenance Log

Routine Maintenance:

Non-Routine Maintenance:

27th Ave LF OM Plan May15

APPENDIX C

MONTHLY COMPRESSOR MAINTENANCE LOG

LOCATION:

DATE: TIME:

TECHNICIAN: WEATHER COND.:

Y N

Additional Comments:

Check Condition of Hoses Check for Warning Lights

Check for Presence of Water in Oil Check for Loose Wiring and Connections Check and Clean Gearcase if Needed

Check Condition of all Fans, Air Paths, Motors, and Drive Gears Clean Cooling System and Check Functionality Check All Oil Elements and Oil Level (Roto Xtend Synthetic Oil - Replace every 2000 Hrs)

Check Various Filters and Filter Elements Check and Adjust Valves and Switches as Needed Check Bolt and Coupling Connections, and Rubber Inserts

Check for Loose Wiring and Connections

Clean Air Intake Chamber

Check and Clean Gearcase if Needed Check Condition of Hoses Check for Warning Lights

Air Compressor #2 Take Service Readings (Air, Oil, Water, Temperature and Pressure) Check for Air, Water, and Oil Leaks

Clean Cooling System and Check Functionality Check All Oil Elements and Oil Level (Roto Xtend Synthetic Oil - Replace every 2000 Hrs) Check for Presence of Water in Oil

Check and Adjust Valves and Switches as Needed Check Bolt and Coupling Connections, and Rubber Inserts Check Condition of all Fans, Air Paths, Motors, and Drive Gears

Clean Air Intake Chamber Check Various Filters and Filter Elements

Check for Air, Water, and Oil Leaks

Air Compressor #1 Atlas Copco N Air Compressor #2 Atlas Copco N

Compressor Maintenance Checklist Notes Air Compressor #1

Take Service Readings (Air, Oil, Water, Temperature and Pressure)

Equipment List ID Make Model No. Serial No. In Operation (Y/N)

COP Monthly Compressor Maintenance Form 27th Ave PROJECT NO.:

J:\Phoenix, City of\LFG OMMCOMP\02 - 27th Ave\27th Ave Non Title V Permit Renewal\Appendices\COP Compressor Maintenance Form.xlsx: 9/5/2025Page 1 of 1

27th Ave LF OM Plan May15

APPENDIX D

SHUTDOWN LOG

27TH Avenue Landfill Landfill Gas Extraction System Shutdown and Deviation Log

Revised RF 11.07.12

Usage: To record all LFGES shutdowns. In the case of multiple consecutive shutdowns, the technician should treat the situation as one event and log the total shutdown time and other information for that event. Reference OM&M Plan during instances of Start-up, Shutdown, and Maintenances.

Year/Month:

Shutdown Date/Time

Start-up Date/Time

Total Shutdown Time

Shutdown Reason

Technician

Shutdown Date/Time

Start-up Date/Time

Total Shutdown Time

Shutdown Reason

Technician

Shutdown Date/Time

Start-up Date/Time

Total Shutdown Time

Shutdown Reason

Technician

Shutdown Date/Time

Start-up Date/Time

Total Shutdown Time

Shutdown Reason

Technician

Corrective Action Taken:

Corrective Action Taken:

Corrective Action Taken:

Corrective Action Taken:

ATTACHMENT B: 27TH AVENUE LANDFILL DUST

CONTROL PLAN

Stationary Source Dust Control Plan (Rev. 24Jan19) Page 2 of 5

Return completed form to:

Maricopa County Air Quality Department 3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 Phone: 602.506.6010 Fax: 602.372.0587 AQPermits@maricopa.gov

RULE 310 DUST CONTROL PLAN (for a facility operating under a Non-Title V, Title V or General Permit)

Documents may be submitted in person at:

3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 or 501 North 44th St, Suite 200, Phoenix, AZ 85008.

Section 2: Site Drawing

Attach a separate page (8½ x 11") with a drawing showing all of the following elements:

Entire facility boundaries Disturbed area with linear dimensions or certification of square footage (including staging areas, stockpiles, access and haul roads, parking, driveways, and storage) Nearest main crossroads North arrow Access point(s) - Planned exit locations onto paved areas accessible to the public Perimeter of unpaved parking lot(s)

Facility Name: 27th Avenue Landfill

Phone: (602) 534-1157 Fax: (602) 534-9872 Email Address: doug.sawyer@phoenix.gov

Type of Permit: Permit Number: 150058

Date

Solid Waste Administrator Company Name: City of Phoenix

General

City: Phoenix

Non-Title V

State: AZ Zip: 85009

1a. Facility Information

Facility Address: 3060 S. 27th Avenue

Type of Facility: Landfill (Closed)

Mailing Address

Title V

Is the mailing address the same as the address given above? ■ NoYes

Facility Name: 27th Avenue Landfill Facility Address: 3060 S. 27th Avenue City: Phoenix State: AZ Zip: 85009

1b. Person responsible for submitting the Dust Control Plan

Printed Name: Stacy Hettmansperger

Signature:

Title:

Mobile:

1c. Person responsible for implementation of the Dust Control Plan

Name: Stacy Hettmansperger

Title: Solid Waste Administrator

On-Site Phone: (602)495-2496 Mobile: Fax:

Email Address: stacy.hettmansperger@phoenix.gov

On-Site Phone: (602) 495-2496 Fax:

Email Address: stacy.hettmansperger@phoenix.gov

Company Name: City of Phoenix

Stationary Source Dust Control Plan (Rev. 24Jan19) Page 2 of 5

Maricopa County Air Quality Department 3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 Phone: 602.506.6010 Fax: 602.372.0587 AQPermits@maricopa.gov

RULE 310 DUST CONTROL PLAN (for a facility operating under a Non-Title V, Title V or General Permit) Documents may be submitted in person at:

3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 or 501 North 44th St, Suite 200, Phoenix, AZ 85008.

Section 2: Site Drawing

Attach a separate page (8½ x 11") with a drawing showing all of the following elements:

Entire facility boundaries Disturbed area with linear dimensions or certification of square footage (including staging areas, stockpiles, access and haul roads, parking, driveways, and storage) Nearest main crossroads North arrow Access point(s) - Planned exit locations onto paved areas accessible to the public Perimeter of unpaved parking lot(s)

Example (simplified, not to scale):

Section 3: Control Measures Control measures must be implemented before, after, and while conducting any dust-generating operation, including during weekends, after work hours, and on holidays.

Primary and Contingency Control Measures

Every category (except Category A) and/or sub-category requires at least one Primary control measure and at least one Contingency control measure. Contingency control measures are the back-up or secondary action(s) that need to be implemented immediately when the primary control measure(s) fail to adequately control dust emissions at the facility.

To indicate your choice, select them in the drop-down lists next to 'primary' or 'contingency'. To add additional measures, click 'Add Primary' or 'Add Contingency' to the right of the drop-downs. To remove measures, click 'Remove Primary' or 'Remove Contingency' to the right of the drop-downs.

City of Phoenix 27th Avenue Landfill [Dust Control Plan]

Perimeter Road for Maintenance Vehicles Only Landfill Surface with Earthen Cap for Closure

1400'

Lower Buckeye Road

4600'

Project Site Elements: I I Entrance (Maintenance Vehicles Only)

Area to be disturbed: As needed for maintenance activities only.

North

27th Avenue

Flare Station

KENDRA.KENT

Rectangle

Stationary Source Dust Control Plan (Rev. 24Jan19) Page 3 of 5

Maricopa County Air Quality Department 3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 Phone: 602.506.6010 Fax: 602.372.0587 AQPermits@maricopa.gov

RULE 310 DUST CONTROL PLAN (for a facility operating under a Non-Title V, Title V or General Permit) Documents may be submitted in person at:

3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 or 501 North 44th St, Suite 200, Phoenix, AZ 85008.

Required Control Measures Some categories have required control measures. Every control measure with a description that begins with 'Required' is a required control measure. In addition to the required primary measure(s), at least one contingency measure must be chosen for these dust-generating operations if they are applicable to your facility (except in Category A).

Categories and/or sub-categories that are not applicable In some categories, when a category and/or sub-category does not apply to the facility, this must be acknowledged by completely filling out the final entry in the category and/or sub-category. An explanation must be supplied for WHY the category and/or sub-category is not applicable. Simply writing “NA” or “not applicable” is not sufficient.

'Other' as a Primary Dust Control Measure If 'Other' is selected as a primary dust control measure in any section of this Plan, then the measure must clearly meet the requirements of Rule 310 for any dust-generating operation. Attach a separate sheet, if needed, for the description. MCAQD will apply the following minimum criteria when evaluating any unlisted dust control measures:

The dust control measure technique is a new or alternative technology that is demonstrated to be equally or more effective in meeting the dust control requirements than the listed dust control measures;

Site logistics do not practically allow for implementation of a listed dust control measure as written (e.g., road width or pre-existing barriers limit the size or width of a gravel pad); and

The owner and/or operator demonstrates that a listed dust control measure is technically infeasible due to site-specific or material-specific conditions, such that implementation of the dust control measure will not provide a benefit in reducing fugitive dust (e.g., pre-soaking screened, washed rock when handling).

After your Permit Application and Dust Control Plan have been approved, you must post your Authority to Operate along with this Dust

Control Plan on-site, as required by Section 4(E) of the General Permit to Operate and/or Construct for Stationary Dust-Generating Sources and County Rule 200, Section 312.

Category A: Wind-Blown Dust If wind conditions cause fugitive dust to exceed the 20% opacity requirement (Rule 310, Section 303.1(a)), then the following actions must be performed.

Note: that there must be a plan to address a possible wind-blown dust event when no one is on site, such as on a weekend or a holiday.

Required: Ensure that all control measures and requirements of the Dust Control Plan are implemented and that violations cannot be prevented by better application, operation, or maintenance of these measures and requirements.

Required: Cease dust-generating operations.

Required: Stabilize any disturbed surface area (as specified in Rule 310, Section 304.3). Select one or more of the following stabilization methods:

Maintain a soil crust. Maintain a threshold friction velocity (TFV) for disturbed surface areas corrected for non-erodible elements of 100 cm/second or higher.

Maintain a vegetative ground cover.

Other:

Required: Compile records consistent with Rule 310, Sections 502 and 503 and document the implementation of control measures and other Dust Control Plan requirements.

Category B: Will Vehicles/Motorized Equipment Be Used on Either of the Following?

B.1 Will Vehicles/Motorized Equipment Be Used on Unpaved Staging Areas, Unpaved Parking Areas, and/or Unpaved Storage Areas?

Yes■ No

Primary Limit vehicle trips (complete additional information below) Add Primary Remove Primary

Contingency Add Contingency Remove Contingency

Stationary Source Dust Control Plan (Rev. 24Jan19) Page 4 of 5

Maricopa County Air Quality Department 3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 Phone: 602.506.6010 Fax: 602.372.0587 AQPermits@maricopa.gov

RULE 310 DUST CONTROL PLAN (for a facility operating under a Non-Title V, Title V or General Permit) Documents may be submitted in person at:

3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 or 501 North 44th St, Suite 200, Phoenix, AZ 85008.

How will vehicle trips be limited?

Limit vehicle trips to no more than 20 per day per road AND limit vehicle speeds to no more than 15 m.p.h. *Note that each trip onto the site and each trip leaving the site counts as one trip. (A round trip to the site counts as two trips.)

Maximum number of vehicle trips on the unpaved parking/staging/material storage areas each day (including number of employee vehicles, earthmoving equipment, haul trucks, and water trucks): 20 Provide a description of how vehicle speeds will be restricted to no more than 15 m.p.h. restricted access and posted speed limit

Specify which area(s) this will apply to: unpaved parking area adjacent to flare station.

B.2 Will Vehicles/Motorized Equipment Be Used on Unpaved Access Areas/Haul Roads? Yes■ No

Primary Limit vehicle trips (complete additional information below) Add Primary Remove Primary

Contingency Add Contingency Remove Contingency

How will vehicle trips be limited?

Limit vehicle trips to no more than 20 per day per road AND limit vehicle speeds to no more than 15 m.p.h. *Note that each trip onto the site and each trip leaving the site counts as one trip. (A round trip to the site counts as two trips.)

Maximum number of vehicle trips on the unpaved parking/staging/material storage areas each day (including number of employee vehicles, earthmoving equipment, haul trucks, and water trucks): 20 Provide a description of how vehicle speeds will be restricted to no more than 15 m.p.h. restricted access and posted speed limit

Specify which area(s) this will apply to: landfill perimeter road

Category C: Bulk Material Handling Note: The requirements in this section are in addition to the track-out control and cleaning requirements in Section E (below).

C.1 Will Materials be Hauled from the Site onto or crossing Areas Accessible to the Public? Yes No■

C.2 Will Materials be Hauled or Tansported within the Boundaries of the Work Site (but will not cross an Area Accessible to the Public)?

Yes No■

C.3 Will Materials be Hauled or Transported within the Boundaries of the Work Site (AND will also cross or access an Area Accessible to the Public while doing so)? Yes No■

If materials will be hauled or transported within the work site by travelling along the side of the work site, and the area where the materials will be hauled is not barricaded to prevent public access, then answer YES to this question.

If materials will be hauled or transported within the work site by travelling across an area accessible to the public, then answer YES to this question.

C.4 Will Bulk Materials be Loaded, Unloaded, and/or Stacked? Yes No■

C.5 Will there be Open Storage Piles for Any Amount of Time? Yes No■

Category D: Trackout, Carry-out, Spillage, and Erosion D.1 Cleaning

Trackout/carry-out must be cleaned up immediately if trackout/carry-out extends a cumulative distance of 25 linear feet or more along a paved area accessible to the public (including curbs, gutters, and sidewalks).

All other trackout/carry-out must be cleaned up no later than the end of the work day. (End of Work Day is the end of a working period that may include one or more work shifts. If working 24 hours a day, the end of a working period shall be considered no later than 8:00 p.m.)

Primary Other (specify below) Add Primary Remove Primary

Stationary Source Dust Control Plan (Rev. 24Jan19) Page 5 of 5

Maricopa County Air Quality Department 3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 Phone: 602.506.6010 Fax: 602.372.0587 AQPermits@maricopa.gov

RULE 310 DUST CONTROL PLAN (for a facility operating under a Non-Title V, Title V or General Permit) Documents may be submitted in person at:

3800 North Central Ave, Suite 1400, Phoenix, AZ 85012 or 501 North 44th St, Suite 200, Phoenix, AZ 85008.

Contingency Add Contingency Remove Contingency

Other: The path of egress from the closed site requires travel on a paved road around an adjacent facility on paved roads.

D.2 Trackout Control Device Does this site have 2 or more acres of disturbed surface area? Yes No■

Will 100 or more cubic yards of bulk material be hauled on-site or off-site each day? Yes No■

Category E: Weed Abatement by Discing or…