SIP REVISION - WASTE MANAGEMENT.PDF
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REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month Year]
Maricopa County Air Quality Department
Phone: 602-506-6010
Fax: 602-506-6179
Maricopa.gov/AQ
CleanAirMakeMore.com
301 West Jefferson Street | Suite 410 | Phoenix, AZ 85003
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TABLE OF CONTENTS
SECTION 1: INTRODUCTION
1.1
Purpose
1.2
Regulatory Background
SECTION 2: COMPLETENESS CRITERIA
2.1
Administrative Materials
2.2
Technical Support
APPENDICES
Appendix 1:
Waste Management Permit Conditions
Appendix 2:
Waste Management Emission Reduction Credit Certification Packages
Appendix 3:
EPA Letter dated August 18, 2021
Appendix 4:
Notice of Public Hearing
Appendix 5:
Board of Supervisors’ Approval
Appendix 6:
Relevant Arizona Revised Statutes
Appendix 7:
Compilation of Public Comments
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Page [ i ]
SECTION 1: INTRODUCTION
1.1
Purpose:
This SIP revision is being submitted to the U.S. Environmental Protection Agency (EPA)
for incorporation of permit conditions from three Waste Management of Arizona, Inc.
(Waste Management) permits into the Arizona SIP. Specifically, the Maricopa County Air
Quality Department (MCAQD) is requesting the EPA approve the following permit
conditions into the Arizona SIP:
Conditions 37-46 of Maricopa County Air Quality Permit P0008308
Conditions 33-42 of Maricopa County Air Quality Permit P0008309
Conditions 37-46 of Maricopa County Air Quality Permit P0008316
The permit conditions above are included in Appendix 1 of this submittal.
1.2
Regulatory Background:
Waste Management recently replaced 225 diesel-fueled solid waste collection trucks with 225
compressed natural gas (CNG) fueled trucks reducing emissions of NOx from four
collection fleets. The four collection fleets are based at three transfer stations within the
Maricopa County ozone nonattainment area. Each transfer station is permitted by MCAQD.
On July 8, 2021, Waste Management submitted an emission reduction credit (ERC)
application to MCAQD to certify the emission reductions for use as emission offsets.
MCAQD representatives reviewed the ERC application to determine if the emission
reductions qualified as permanent, quantifiable, surplus, enforceable, and real as required by
40 CFR 51.165(a)(3)(ii)(A) through (D) and 40 CFR 51.165(a)(3)(ii)(G). MCAQD
representatives determined the emission reductions qualified as quantifiable, surplus, and
real and could qualify as permanent and enforceable with revisions to the three transfer
station air quality permits associated with the four collection fleets.
In August of 2021, MCAQD revised Waste Management permits P0008308, P0008309, and
P0008316 to include permit conditions to make the emission reductions permanent and
enforceable. The permits were revised to include a condition that the replaced diesel-fueled
trucks be either permanently disabled or permanently removed from the nonattainment area
and a condition that future replacement trucks of the CNG trucks be only with trucks
certified to a NOx emission limit equivalent to or less than the CNG trucks. In addition, the
permits were revised to include monitoring and recordkeeping requirements to make the
reductions enforceable.
After MCAQD revised the Waste Management permits MCAQD certified 33.6 tons/year
of emission reduction credits. The Waste Management Emission Reduction Certification
Packages are included in Appendix 2.
To further ensure the permanency of the Waste Management emission reductions the EPA
directed the MCAQD to submit the Waste Management permit conditions related to the
emission reduction credits for approval into the Arizona SIP. See the EPA letter included in
Appendix 3 for further details.
The Maricopa County Board of Supervisors approved submittal of the Waste Management
permit conditions into the Arizona SIP on [date].
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SECTION 2: COMPLETENESS CRITERIA
2.1
Administrative Materials:
2.1(a) A formal letter of submittal from the MCAQD Director or [his] designee,
requesting the EPA approval of the SIP revision.
See SIP submission cover letter from Philip A. McNeely, Director of MCAQD,
included above.
2.1(b) Evidence that MCAQD has adopted the SIP revision in the State code or
body of regulations; or issued the permit, order, consent agreement in final
form.
The Maricopa County Board of Supervisors approved submittal of the permit
conditions into the Arizona SIP on [date].
See Appendix 5 of this document.
2.1(c) Evidence that MCAQD has the necessary legal authority under State law
to adopt and implement the SIP revision.
Arizona Revised Statutes (A.R.S.) §§ 49-112, 49-474, 49-479 and 49-480 authorize
MCAQD to submit revisions to the SIP for approval.
See Appendix 6 of this document.
2.1(d) A copy of the actual regulations, or documents submitted for approval and
incorporation by reference into the plan, including indication of the changes
made to the existing approved plan, where applicable.
See Appendix 1 of this document which includes the ERC permit conditions from
MCAQD air quality permits P0008308, P0008309, and P0008316.
2.1(e) Evidence that MCAQD followed all of the procedural requirements of the
State’s laws and constitution in conducting and completing the
adoption/issuance of the plan.
MCAQD completed all of the following procedural requirements for obtaining
approval of the SIP submittal:
(1)
Provided the public at least 30 days to comment on the draft SIP submittal
(BOS Public Hearing Notice and Newspaper Affidavit); and
(2)
Obtained approval to submit the permit conditions as a revision to the
Arizona SIP from the Board of Supervisors (Certified Minutes of
BOS Public Hearing [Date]).
See Appendices 4 and 5
2.1(f) Evidence that public notice was given of the proposed change consistent with
procedures approved by the EPA, including the date of publication of such
notice.
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See Appendix 4 for evidence that MCAQD gave public notice of the proposed
SIP submittal, including the date of publication of such notice.
2.1(g) Certification that public hearing(s) were held in accordance with the
information provided in the public notice and the State’s laws and
constitution, if applicable and consistent with the public hearing
requirements in 40 CFR 51.102.
See Appendix 5.
2.1(h) Compilation of public comments and the MCAQD’s response.
Appendix 7 includes a compilation of public comments and MCAQD’s
responses.
2.2
Technical Support:
2.2(a) Identification of all regulated pollutant(s) affected by the plan.
The regulated pollutant affected by this plan is NOx.
2.2(b) Identification of the locations of affected sources including the EPA
attainment/nonattainment designation of the locations and the status of the
attainment plan for the affected area(s).
The affected sources are mobile sources, solid waste collection trucks, traveling in
the ozone nonattainment area.
2.2(c) Quantification of the changes in plan allowable emissions from the affected
sources; estimates of changes in current actual emissions from affected
sources or, where appropriate, quantification of changes in actual emissions
from affected sources through calculations of the differences between certain
baseline levels and allowable emissions anticipated as a result of the revision.
Waste Management’s replacement of 225 diesel-fueled solid waste collection trucks
with 225 CNG fueled trucks reduced emissions of NOx by 33.6 tons/year.
2.2(d) The MCAQD’s demonstration that the national ambient air quality standards,
EPA attainment/nonattainment designations for all or parts of Maricopa County are:
1987 PM10 Standard:
Serious Nonattainment (June 10, 1996)
2008 Ozone Standard:
Moderate Nonattainment (May 4, 2016)
2015 Ozone Standard:
Marginal Nonattainment (June 4, 2018)
1971 Carbon Monoxide Standard:
Attainment (April 8, 2005)
2008 Lead Standard:
Unclassified/Attainment (December 31, 2011)
2010 Nitrogen Oxides Standard:
Unclassified/Attainment (January 31, 2012)
2010 Sulfur Dioxide Standard:
Unclassified/Attainment (April 19, 2018)
2012 PM2.5 Standard:
Unclassified/Attainment (April 15, 2015)
The status of attainment plans for Maricopa County are:
2012 Five Percent Plan:
Approved (June 10, 2014)
2017 MAG Ozone Moderate Plan:
Partial Approval/Partial Disapproval (June 2, 2020)
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prevention of significant deterioration increments, reasonable further progress
demonstration, and visibility, as applicable, are protected if the plan is
approved and implemented.
The national ambient air quality standards, prevention of significant deterioration
increments, reasonable further progress demonstration, and visibility are protected if
the plan is approved because approval of the plan is ensuring the permanence of the
Waste Management emission reductions.
2.2(e) Modeling information required to support the proposed revision, including
input data, output data, models used, justification of model selections,
ambient monitoring data used, meteorological data used, justification for use
of offsite data (where used), modes of models used, assumptions, and other
information relevant to the determination of adequacy of the modeling
analysis.
Not applicable.
2.2(f) Evidence, where necessary, that emission limitations are based on continuous
emission reduction technology.
Not applicable.
2.2(g) Evidence that the plan contains emission limitations, work practice standards
and recordkeeping/reporting requirements, where necessary, to ensure
emission levels.
See Appendix 1: Waste Management Permit Conditions
2.2(h) Compliance/enforcement strategies, including how compliance will be
determined in practice.
The MCAQD will determine compliance by conducting periodic inspections and
ensuring compliance with the permit conditions. Enforcement will be conducted per
current department policies and procedures.
2.2(i) Special economic and technological justifications required by any applicable
EPA policies, or an explanation of why such justifications are not necessary.
Not applicable.
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REVISION TO ARIZONA’S SIP
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
APPENDIX 1:
WASTE MANAGEMENT PERMIT CONDITIONS
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INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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MARICOPA COUNTY AIR QUALITY DEPARTMENT
Permitting Division
3800 N. Central Avenue, Suite 1400, Phoenix, Arizona 85012
Phone: (602) 506-6010
Fax: (602) 506-6985
AIR QUALITY PERMIT TO OPERATE AND/OR CONSTRUCT
(As required by Title 49, Chapter 3, Article 2, Section 49-480, Arizona Revised Statutes)
ISSUED TO
San Tan Transfer Station
4040 S 80th St
Mesa, AZ 85212
This air quality permit to operate and/or construct does not relieve the applicant of the
responsibility of meeting all air pollution regulations.
THE PERMITTEE IS SUBJECT TO THE SPECIFIC AND GENERAL CONDITIONS IDENTIFIED IN THIS PERMIT.
FACILITY NUMBER:
F001645
LEGACY PERMIT NUMBER:
040027
PERMIT NUMBER:
P0008308
REVISION DATE:
08/25/2021
EXPIRATION DATE:
06/30/2024
Todd Martin, Non-Title V Permit Supervisor
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San Tan Transfer Station, Facility # F001645
Permit # P0008308
Revision Date: 08/25/2021
[SIP Rule 220 §302.2] [Rule 204 §305.2.a]
42. Monitoring of Equipment Use:
The Permittee shall monitor the use of all CNG-powered equipment used to generate ERCs to verify that the
equipment is operated in the same manner as was represented in the ERC application, specifically the
emission calculations using Motor Vehicle Emission Simulator (MOVES) software. This monitoring shall
include the follow, at minimum:
a.
Vehicle miles traveled (VMT) for each CNG-powered vehicle;
b.
Percent of VMT within the nonattainment area.
[SIP Rule 220 §302.2] [Rule 204 §305.2.b]
43. Removal/Disposal of Replaced Equipment:
a.
The Permittee shall permanently remove any replaced diesel-powered equipment from the nonattainment
area or render the replaced equipment permanently disabled and dispose of in a manner that complies
with all applicable local, state, and federal laws. For future CNG-powered equipment replacements, the
Permittee shall provide evidence of proper disposal upon request from the Control Officer or from the
permitted source using the ERCs as offsets. Evidence shall include at a minimum, serial numbers or
vehicle numbers if the vehicle number is linked in the Permittee’s records to the serial number, and
location of where or how the equipment was disposed or removed from the nonattainment area.
b.
The Permittee shall monitor the location and usage of CNG-powered vehicles that were used to create
ERCs and have been replaced but remain operational outside the ozone nonattainment area. Such
monitoring shall include the following, at minimum:
i.
Name and address of the current owner of the vehicle;
ii.
Documentation showing the current owner’s geographic coverage area;
iii.
Description of current vehicle usage including the following:
1)
Customer names;
2)
Pickup and delivery locations (address or equivalent).
[SIP Rule 220 §302.2] [Rule 204 §305.2.d]
44. Inspections:
The Permittee shall allow the Control Officer access to the premises for conducting an inspection to
verify compliance with requirements applicable to ERCs and their continued achievement. An
inspection may include, but is not limited to, a review of records and reports.
[SIP Rule 220 §302.2] [Rule 204 §502]
45. Recordkeeping:
a.
Records shall be maintained on site at all times by the Permittee in a consistent and complete manner, in
either electronic or paper format.
b.
Records shall be made available upon request and without delay to the owner or operator of the permitted
source utilizing the ERCs and the Control Officer or his designee.
c.
Records shall be maintained for five (5) years beyond the use or retirement of the ERCs, or five years
after the retirement of a CNG-powered vehicle which was used to generate ERCs. The ERCs are to be
used as offsets for Intel Corporation, facility # F000701, permit # P0006742.
[SIP Rule 220 §302.2] [Rule 204 §501]
d.
CNG-powered equipment: Records shall include a detailed inventory of all CNG-powered equipment
used to generate ERCs including all of the following for each piece of equipment:
i.
The equipment manufacturer.
ii.
The model number.
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San Tan Transfer Station, Facility # F001645
Permit # P0008308
Revision Date: 08/25/2021
iii.
The model year.
iv.
A description of the equipment.
v.
Information on sources used to obtain family or test group, fuel capacities, and emission rates of
each CNG-powered vehicle when used to calculate ERCs.
vi.
The date each CNG-powered vehicle was:
1)
Added to the inventory.
2)
Removed from the inventory.
vii. Any maintenance performed on a vehicle including the following, at minimum:
1)
A description of the maintenance;
2)
The date that the maintenance was performed;
3)
The effect of the maintenance on the continued achievement of the ERCs.
e.
Diesel-powered vehicle: Records shall include a detailed inventory of all diesel-powered vehicle used for
the same purpose as CNG-powered vehicle including all of the following for each vehicle:
i.
The vehicle manufacturer.
ii.
The model number.
iii.
The model year.
iv.
A description of the vehicle including serial number.
v.
Fuel type.
vi.
The date each vehicle was:
1)
Added to the inventory.
2)
Removed from the inventory.
f.
Monthly review and, if necessary, update the vehicle inventory.
g.
Operational Records:
i.
Monthly: For each CNG-powered vehicle used to generate ERCs, the Permittee shall record a
description of all maintenance and repairs and at least one of the following to demonstrate the vehicle
is used in the same manner as was represented in the ERC application, most notably the calculations
using Motor Vehicle Emission Simulator (MOVES) software:
1)
Hours of operation.
2)
Mileage accrued.
ii.
Monthly: For each piece of diesel-fueled vehicle that can be used for the same purpose as the CNG-
powered vehicle used to generate ERCs, the Permittee shall record a description of all maintenance
and repairs and at least one of the following:
1)
Hours of operation.
2)
Mileage accrued.
3)
Fuel consumed.
h.
Replacement of diesel vehicles:
For any diesel vehicle that is replaced with a higher emitting vehicle, the Permittee shall notify the
Department by the end of the month following the vehicle replacement so the Department can review
Permittee records to ensure the ERCs continue to meet applicable requirements.
[SIP Rule 220 §302.2][Rule 204 §505]
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MARICOPA COUNTY AIR QUALITY DEPARTMENT
Engineering and Permitting Division
3800 N. Central Avenue, Suite 1400, Phoenix, Arizona 85012
Phone: (602) 506-6010
Fax: (602) 506-6985
AIR QUALITY PERMIT TO OPERATE AND/OR CONSTRUCT
(As required by Title 49, Chapter 3, Article 2, Section 49-480, Arizona Revised Statutes)
ISSUED TO
White Tanks Transfer Station
18605 W McDowell Rd
Goodyear, AZ 85338
This air quality permit to operate and/or construct does not relieve the applicant of the
responsibility of meeting all air pollution regulations.
THE PERMITTEE IS SUBJECT TO THE SPECIFIC AND GENERAL CONDITIONS IDENTIFIED IN THIS PERMIT.
FACILITY NUMBER:
F001646
LEGACY PERMIT NUMBER:
040086
PERMIT NUMBER:
P0008309
REVISION DATE:
08/25/2021
EXPIRATION DATE:
10/31/2024
Todd Martin, Non-Title V Permit Supervisor
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White Tanks Transfer Station Facility# F001646
Permit#: P0008309
Revision Date: 08/25/2021
[SIP Rule 220 §302.2] [Rule 204 §305.1.a]
36. Quantification of Baseline Emissions and Emission Reductions:
a.
The Permittee’s documentation to quantify baseline emissions and emission reductions shall comply with
the methodology given in Rule 204 Appendix C and with emission factors in grams per mile traveled
(g/mile) or comparable units based on application documents, most notably the calculations using Motor
Vehicle Emission Simulator (MOVES) software.
b.
ERC quantification calculations shall not include emission reductions created or used under any other
emissions trading program, emission reductions used to satisfy the State Implementation Plan
including transportation conformity requirements, or any emission reductions pursuant to a federal
consent decree, or state and local settlements.
[SIP Rule 220 §302.2] [Rule 204 §§305.1.b & c]
37. Operation and Maintenance of CNG-Powered Vehicles:
The Permittee shall operate and maintain CNG-powered vehicles in accordance with the manufacturer’s
written instructions and maintenance program in order to ensure the continued generation of emission
reductions. Vehicle operation and maintenance shall be documented in accordance with Permit Condition
41.d.vii.
[SIP Rule 220 §302.2] [Rule 204 §305.2.a]
38. Monitoring of Equipment Use:
The Permittee shall monitor the use of all CNG-powered equipment used to generate ERCs to verify that the
equipment is operated in the same manner as was represented in the ERC application, specifically the
emission calculations using Motor Vehicle Emission Simulator (MOVES) software. This monitoring shall
include the follow, at minimum:
a.
Vehicle miles traveled (VMT) for each CNG-powered vehicle;
b.
Percent of VMT within the nonattainment area.
[SIP Rule 220 §302.2] [Rule 204 §305.2.b]
39. Removal/Disposal of Replaced Equipment:
a.
The Permittee shall permanently remove any replaced diesel-powered equipment from the nonattainment
area or render the replaced equipment permanently disabled and dispose of in a manner that complies
with all applicable local, state, and federal laws. For future CNG-powered equipment replacements, the
Permittee shall provide evidence of proper disposal upon request from the Control Officer or from the
permitted source using the ERCs as offsets. Evidence shall include at a minimum, serial numbers or
vehicle numbers if the vehicle number is linked in the Permittee’s records to the serial number, and
location of where or how the equipment was disposed or removed from the nonattainment area.
b.
The Permittee shall monitor the location and usage of CNG-powered vehicles that were used to create
ERCs and have been replaced but remain operational outside the ozone nonattainment area. Such
monitoring shall include the following, at minimum:
i.
Name and address of the current owner of the vehicle;
ii.
Documentation showing the current owner’s geographic coverage area;
iii.
Description of current vehicle usage including the following:
1)
Customer names;
2)
Pickup and delivery locations (address or equivalent).
[SIP Rule 220 §302.2] [Rule 204 §305.2.d]
40. Inspections:
The Permittee shall allow the Control Officer access to the premises for conducting an inspection to
verify compliance with requirements applicable to ERCs and their continued achievement. An
inspection may include, but is not limited to, a review of records and reports.
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White Tanks Transfer Station Facility# F001646
Permit#: P0008309
Revision Date: 08/25/2021
[SIP Rule 220 §302.2] [Rule 204 §502]
41. Recordkeeping:
a.
Records shall be maintained on site at all times by the Permittee in a consistent and complete manner, in
either electronic or paper format.
b.
Records shall be made available upon request and without delay to the owner or operator of the permitted
source utilizing the ERCs and the Control Officer or his designee.
c.
Records shall be maintained for five (5) years beyond the use or retirement of the ERCs, or five years
after the retirement of a CNG-powered vehicle which was used to generate ERCs. The ERCs are to be
used as offsets for Intel Corporation, facility # F000701, permit # P0006742.
[SIP Rule 220 §302.2] [Rule 204 §501]
d.
CNG-powered equipment: Records shall include a detailed inventory of all CNG-powered equipment
used to generate ERCs including all of the following for each piece of equipment:
i.
The equipment manufacturer.
ii.
The model number.
iii.
The model year.
iv.
A description of the equipment.
v.
Information on sources used to obtain family or test group, fuel capacities, and emission rates of
each CNG-powered vehicle when used to calculate ERCs.
vi.
The date each CNG-powered vehicle was:
1)
Added to the inventory.
2)
Removed from the inventory.
vii. Any maintenance performed on a vehicle including the following, at minimum:
1)
A description of the maintenance;
2)
The date that the maintenance was performed;
3)
The effect of the maintenance on the continued achievement of the ERCs.
e.
Diesel-powered vehicle: Records shall include a detailed inventory of all diesel-powered vehicle used for
the same purpose as CNG-powered vehicle including all of the following for each vehicle:
i.
The vehicle manufacturer.
ii.
The model number.
iii.
The model year.
iv.
A description of the vehicle including serial number.
v.
Fuel type.
vi.
The date each vehicle was:
1)
Added to the inventory.
2)
Removed from the inventory.
f.
Monthly review and, if necessary, update the vehicle inventory.
g.
Operational Records:
i.
Monthly: For each CNG-powered vehicle used to generate ERCs, the Permittee shall record a
description of all maintenance and repairs and at least one of the following to demonstrate the vehicle
is used in the same manner as was represented in the ERC application, most notably the calculations
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MARICOPA COUNTY AIR QUALITY DEPARTMENT
Engineering and Permitting Division
3800 N. Central Avenue, Suite 1400, Phoenix, Arizona 85012
Phone: (602) 506-6010
Fax: (602) 506-6985
AIR QUALITY PERMIT TO OPERATE AND/OR CONSTRUCT
(As required by Title 49, Chapter 3, Article 2, Section 49-480, Arizona Revised Statutes)
ISSUED TO
DEER VALLEY TRANSFER STATION
2120 W ADOBE DR
PHOENIX, AZ 85027
This air quality permit to operate and/or construct does not relieve the applicant of the
responsibility of meeting all air pollution regulations.
THE PERMITTEE IS SUBJECT TO THE SPECIFIC AND GENERAL CONDITIONS IDENTIFIED IN THIS PERMIT.
FACILITY NUMBER:
F000443
LEGACY PERMIT NUMBER:
000024
PERMIT NUMBER:
P0008316
REVISION DATE:
08/25/2021
EXPIRATION DATE:
04/30/2025
Todd Martin, Non-Title V Permit Supervisor
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Deer Valley Transfer Station Facility # F000443
Permit # P0008316
Revision Date: 08/25/2021
43. Removal/Disposal of Replaced Equipment:
a.
The Permittee shall permanently remove any replaced diesel-powered equipment from the nonattainment
area or render the replaced equipment permanently disabled and dispose of in a manner that complies
with all applicable local, state, and federal laws. For future CNG-powered equipment replacements, the
Permittee shall provide evidence of proper disposal upon request from the Control Officer or from the
permitted source using the ERCs as offsets. Evidence shall include at a minimum, serial numbers or
vehicle numbers if the vehicle number is linked in the Permittee’s records to the serial number, and
location of where or how the equipment was disposed or removed from the nonattainment area.
b.
The Permittee shall monitor the location and usage of CNG-powered vehicles that were used to create
ERCs and have been replaced but remain operational outside the ozone nonattainment area. Such
monitoring shall include the following, at minimum:
i.
Name and address of the current owner of the vehicle;
ii.
Documentation showing the current owner’s geographic coverage area;
iii.
Description of current vehicle usage including the following:
1)
Customer names;
2)
Pickup and delivery locations (address or equivalent).
[SIP Rule 220 §302.2] [Rule 204 §305.2.d]
44. Inspections:
The Permittee shall allow the Control Officer access to the premises for conducting an inspection to
verify compliance with requirements applicable to ERCs and their continued achievement. An
inspection may include, but is not limited to, a review of records and reports.
[SIP Rule 220 §302.2] [Rule 204 §502]
45. Recordkeeping:
a.
Records shall be maintained on site at all times by the Permittee in a consistent and complete manner, in
either electronic or paper format.
b.
Records shall be made available upon request and without delay to the owner or operator of the permitted
source utilizing the ERCs and the Control Officer or his designee.
c.
Records shall be maintained for five (5) years beyond the use or retirement of the ERCs, or five years
after the retirement of a CNG-powered vehicle which was used to generate ERCs. The ERCs are to be
used as offsets for Intel Corporation, facility # F000701, permit # P0006742.
[SIP Rule 220 §302.2] [Rule 204 §501]
d.
CNG-powered equipment: Records shall include a detailed inventory of all CNG-powered equipment
used to generate ERCs including all of the following for each piece of equipment:
i.
The equipment manufacturer.
ii.
The model number.
iii.
The model year.
iv.
A description of the equipment.
v.
Information on sources used to obtain family or test group, fuel capacities, and emission rates of
each CNG-powered vehicle when used to calculate ERCs.
vi.
The date each CNG-powered vehicle was:
1)
Added to the inventory.
2)
Removed from the inventory.
vii. Any maintenance performed on a vehicle including the following, at minimum:
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
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DRAFT
Deer Valley Transfer Station Facility # F000443
Permit # P0008316
Revision Date: 08/25/2021
1)
A description of the maintenance;
2)
The date that the maintenance was performed;
3)
The effect of the maintenance on the continued achievement of the ERCs.
e.
Diesel-powered vehicle: Records shall include a detailed inventory of all diesel-powered vehicle used for
the same purpose as CNG-powered vehicle including all of the following for each vehicle:
i.
The vehicle manufacturer.
ii.
The model number.
iii.
The model year.
iv.
A description of the vehicle including serial number.
v.
Fuel type.
vi.
The date each vehicle was:
1)
Added to the inventory.
2)
Removed from the inventory.
f.
Monthly review and, if necessary, update the vehicle inventory.
g.
Operational Records:
i.
Monthly: For each CNG-powered vehicle used to generate ERCs, the Permittee shall record a
description of all maintenance and repairs and at least one of the following to demonstrate the vehicle
is used in the same manner as was represented in the ERC application, most notably the calculations
using Motor Vehicle Emission Simulator (MOVES) software:
1)
Hours of operation.
2)
Mileage accrued.
ii.
Monthly: For each piece of diesel-fueled vehicle that can be used for the same purpose as the CNG-
powered vehicle used to generate ERCs, the Permittee shall record a description of all maintenance
and repairs and at least one of the following:
1)
Hours of operation.
2)
Mileage accrued.
3)
Fuel consumed.
h.
Replacement of diesel vehicles:
For any diesel vehicle that is replaced with a higher emitting vehicle, the Permittee shall notify the
Department by the end of the month following the vehicle replacement so the Department can review
Permittee records to ensure the ERCs continue to meet applicable requirements.
[SIP Rule 220 §302.2][Rule 204 §505]
46. Annual Reporting:
The Permittee shall submit a report to the Control Officer annually by March 1 for the most recent calendar
year. The report shall include the following, at minimum:
a.
The quantity of ERCs, the vehicles used to generate the ERCs, and the identification of the vehicles, and
their location and usage.
b.
A summary of the operation and maintenance of vehicles for the continued achievement of the ERCs.
The summary shall include the following, at minimum:
i.
A description of maintenance performed to ensure vehicle emissions remain at the level necessary
to achieve the ERCs;
ii.
A description of vehicle usage as it relates to emissions to ensure continued achievement of the
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
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Return to Table of Contents
REVISION TO ARIZONA’S SIP
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
APPENDIX 2:
WASTE MANAGEMENT EMISSION REDUCTION CREDIT CERTIFICATION
PACKAGES
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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Page 21 of 73
DRAFT
August 25, 2021
Daniel Czecholinski
Philip A. McNeely, R.G. Director
Phone: 602-506-6701
Email: Philip.McNeely@maricopa.gov
Maricopa.gov I AQ
CleanA irMakeMore.com
J\.ir Quality Division Director
Arizona Department of Environmental Quality
1110 West Washington Street
Phoenix, Arizona 85007
RE:
Emissions Reduction Certification (ERC)
Waste Management of Arizona, Inc. (Santan Transfer Station) - MCAQD Facility F001645
Dear Mr. Czecholinski:
The Maricopa County J\.ir Quality Department (IYICAQD) has verified the credit and number of
tons of actual emissions that have been reduced by replacing diesel-fueled solid waste collection
trucks with CNG-fueled tlucks based at the Waste Management Santan Transfer Station located at
4040 South 80th Street in Mesa, _Arizona. In accordance with the Arizona Administrative Code, the
following actual emissions have been verified for use as certified emission credits:
Nitrogen Oxides (NOx): 18.3 tons/year
Per Maricopa County Rule 204 §301 and AAC Rule 18-2-1205.A, the Control Officer may certify an
emission credit if the credit is verified and determined by all of the following:
1. A reduction in actual emissions that occurred after August 17, 1999.
The facility has replaced 129 diese/ft1e/ed solid waste co//ectio11 tn1cks with 129 CNGft1eled solid waste co!!ettion
!tucks. Actt1al NOx emissions from CNG tn1cks are 65 - 90% less than dieselft1eled trucks depe11di11g 011 mode/
yem:
2. A quantifiable reduction in actual emissions.
The applicant sttbmitted ca/c11/ations ttsing EPA 's LVIotor Vehicle Emissions S imttlator so.fiware (v3. 01) to qt1C1ntijj
emissiom from both the old and new trucks. Actttai vehide mi/es tmveled were also provided to define the act11al
emissiom. Emission baseline from the dieseift1eled tr11cks has been calcttlated over a seties efyears (i.e., 2013-2021)
depending on when the actttal conversion occmrecl.
3. A permanent reduction in actual emissions.
The trucks removed from sm1ice must be disabled or moued outside of the JVfaricopa Cot111ry 11011-attaimmnt area as
req11ired in the site air quali!J permit P0008308. The permit a/so req11ires that airy ft1t11re replacement of trt1cks
mttst be eqttal to or lower emitting than the tr11ck beillg replaced. These e1iforceable pmvit conditions make the
emission red11ctio11s pe1ma11e11t.
Return to Table of Contents
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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DRAFT
Daniel Czechollnski
Dole: August 25. 2021
Page 2 of 2
4. An enforceable reduction in actual emissions.
The air quality permit (i.e., P0008308) for the facility includes provisions reqt1ili11g removal of the dieselfired tn1cks
that J.JJere replaced f?J the CNGjired tn1cks be removed from the lvlmicopa Co1111(y ozone 11011-attai11ment a red.
Additional conditions in the pe1mit req11ire monitoring and record keeping to f11rther make the redt1ctio11s enforceable.
5. A sutplus reduction in actual emissions occurring in addition to any other required emission
reduction.
The type of tmcks that formed the hasis for the emission credit have bee11 listed i11 the 2017 Ozone Pe1iodic Emission
Inventory (PEI) and previous PEis as dieself11eled vehicles. These i11ve11tolies are ttsed for regional pla1111ing f?y the
J\!Ian'cupa Association of Governments. No e1J1issio11redttctiom1verc reqttired at the sotm:e either through pla1111i11g or
reg11/ation that wo11ld reduce the certified credits. Therefore, the /mver emitting CNGjired tn1cks are s111plt1s to the
i11ventory. Co11seqt1e11t!J, the table be/01v is ct s11111mary of the emission credit calcttlatio11.
Pollutant
Baseline Emissions
Ongoing Emissions
Certified Credits
(tons/year)
(tons/vear)
(tons/year)
NOx
23.4
5.1
18.3
Based on the information submitted by the souxce and verified as described above, the MCAQD
certifies emission reduction credits in the amount of 18.3 tons of N Ox.
This notification is being provided to the Arizona Department of Environmental Quality in the
event the applicant submits the certified ERCs for deposit in the Arizona Emissions Bank.
If you have any questions or need additional information, please contact Richard Sumner of my staff
at Richard.sumner@maricopa.gov or 602-506-1842.
Sincerely,
t!fti!:<~
Director
Maricopa County Air· Quality Department
Cc:
David Bearden, Waste Management of Arizona, Inc.
Attachments
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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DRAFT
Emission Reduction Credit
Evaluation
Source: Waste Management (Santan Transfer Station)
Facility ID: F001645
Permit: P0008308
Date: August 11, 2021
Project Description: Replace diesel-powered solid waste collection trucks with CNG-powered trucks.
Baseline Emissions: CNG trucks were brought into the fleet over a number of years. Therefore, the baseline is the diesel truck that was
replaced by the CNG truck. For example, the NOx emission rate from the diesel truck was 5.29 g/mile and CNG truck #211914
emission rate put into service in 2015 is 1.76 g/mile. (Emission rates based on EPA MOVES 3.01.) The reduction is the difference
between the baseline diesel truck emission rate and the CNG truck emission rate. Credits are reduced by 2.5% to allow for
mileage outside of the non-attainment area. Annual mileage used in the calculation is 97.5% of actual average mileage for each
individual truck. Note: Santan Transfer Station includes both Santan Fleet and Elwood Fleet.
Example Calculation (1 Truck): (5.29 g/mile - 1.76 g/mile) x 35,649 miles/year x 0.975 = 122,695 g/yr = 0.135 tons/year
Total NOx from the attached spreadsheet for 73 trucks (Santan Fleet)= 10.6954 tons (uncorrected for outside non attainment area)
Total Creditable NOx (after correction)= 10.6954 tons (97.5/97.51) = 10.7 tons
Creditable NOx reduction (Santan Fleet)= 10.7 tons
Total NOx from the attached spreadsheet for 56 trucks (Elwood Fleet)= 7.7929 tons (uncorrected for outside non attainment area)
Total Creditable NOx (after correction)= 7.7929 tons (97.5/100) = 7.6 tons
Creditable NOx reduction (Elwood Fleet)= 7.6 tons
Total Creditable NOx reduction= 10.7 + 7.6 = 18.3 tons
Prepared by Richard Sumner
August 11, 2021
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
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DRAFT
Relurn complelecl form lo
Maricopa County Air Quallly Deportment
3800 l•lorth Central Ave Svile 1400. Phoenix AZ 850 12
Phone: 602.506.60 10 fox. 602.372.0587
AQPermil s ii'm ail.moricopo.gov
3800 t·lort>1 Central A•1e. 5uile I ~00 . Phoenix. AZ 85012 or 50 1 l•lorlh <14th St, Suite 200 Pnoen1.< AZ 850013.
Emission Reduction Credit Application
F:ml.tl)• lnfonnarion
1. Facility Name:
Waste i\lanagement of Arizona, Inc.
222 S. ~Iill :\ve., Suite 333
2. Faciltty Address:
City:
Tempe
State: .-\rizona
Zip Code: 85281
3. Permit#:
040086/FOOl646 (White Tnnks)g t'>!.\oai.? /roa\t:.'-f.5 { Sl\i'l'fA-'1l·oc:ioG83S/~DMLl43 ( b~J~~I
Contact Information
I
4. Is the facility information the same as the contact infonnat1on?
YesO
No l2J
5. Contact Name: Dave Bearden
222 S. ~1111 :\vc., Suite 333
6. Conract _-\ddress:
City:
Tempe
Srnte:
Arizona
Zip Code: 85281
7. Pollutant (Complete a separate sheet for each pollutant):
NOx
8. Date:
Jun 28, 2021
9. List of the equipmenr/process involved with the emission reduction:
Solid Waste Collection Trucks converted from diesel fuel to compressed natural gas
I Add a Rnw IDcletc a Rov.
10. Describe how the emission reduction will be accomplished:
Waste Management has been con\'erting the majority of their solid waste collection truck neets in the Phocni.."\: area from diesel fuel co
Compressed Natuml Gas (CNG), and is applring for NOx Emissions lleducuon Credits (ERCs) from the voluntaxy conversion of trucks
from diesel to CNG operation. The trucks arc associated with four collection fleets operate at three transfer stauons m the non-
attainment area. :\ttachmcnt A pro\•ides gualifying crircria, mechod of calculauons and fleet calculauons which have bern met in the
generation of these ERCs.
11. Estimated date of emission reduction: various sec attachment:\
12. Describe how rhe reduction will be made permancnr:
13. Baseline period (two calendar years):
2020
2021
If rhis is not the most recent cwo calendar years, pro\'idc a detailed explanation of why the most recent years were not used.
111e requin:mcnts related to the ERCs will be included with pennit modification for the tl"'ilnsfcr srntions \\'hitc Tanks, Deer Valley and
San Tan. The proposed requirements celarc to I) \'V?lf will continue to purchase CNG trucks or alternative trucks with at least or better
NOx emissions compared to the cucrenr Cummins Engine, 2) perform routine engine maintenance and 3) maintain ar least 22 trucks
operating 95% or more of their time in the Non-attainment Arca.
14. Identify the method that is proposed to calculatc rhc baseline emissions and how that method is being uscd. {Examples: matcrlnl
balance, performance test data, continuous momtor, crrussion factors, etc.)
Sec Attachment i\ - Criteria, Methods of Calculations and Fleet Calculations
RcviscJ 13Marl9
!'age 1 of'.!.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
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DRAFT
f' 'IJll C JI• f r·
l · ::•;
'.
Maricopa County A'r Quality Deportmeril
33'J{ , ., 11
r_ ~~:}' ·.JI \
•: · · '! 1
1 ··r, .n
•\/ ( 1· )' 1
15. Llsr rhe seasonal emission rate on a quartcrlr basis from the opcr:ition/ process that provided the emission reduction.
Bnschnc Ycnr One
2020
~[:
<.J2:
t.l3:
~4:
Bnsehne \\-ar Two
2021
QI:
Q2:
Q3:
Q4:
16. Calculation of base\Jnc cm1ss1ons m tons per year:
.\. List anr emission factors wirh rhc1r source (mcludc unirs):
Sec :\ttachmcnt :\
I Add :i Row IDclctc :i Ro"
6 , List assumpt10ns made to perform the cakulauons:
Sec ;\tt:ichmcnt .-\
C. Show s;imple of c;1lcubt10ns made ro nrify cm1ss1on reducuon:
Sec :\nachmcnt ;\
D. Baseline emission rntc: (tons per year}:
3Y.14
E. Provide a list of documents attached to substantiate the lmsis for the cnlculatlom (e.g., safety data sheets, process records,
matcnal use records, monttonng records, etc.).
Sec :\trnchmcnt .:\
j Add a Row., Ddcu: a Row
F. Comml'nts or add1t1onal 1nfonnauon:
17. Do you plan to register the ceruficd credits m the .-\nzona Em1ss1ons Bank administered by the ;\rizon:i Department of
Enmonml'ntal Qua~ty (. \DEQ)?
IZ]Ycs
0 No
If yes, tht're ls a registration fee of S200 parable to .-\ DEQ. For more
1nform:111on about the ~\nzona Etl1lss1ons B:1nk please CC\1CW :\nzona :\dmrn1strat1vc Code Title I 8, Chnptcr 2, :\rnclc 12.
18. r ceruf)· that the statements nnd information prO\·ided herein arc true, accur;itc, and complete based on mformation and belief formed
a[tcr reasonable inquiry.
-
Stgnaturc of owner or rcspnnsthle official: I ~~wl...
I
Trpc: or print name and utlc : I
o~ ~lLr~
I
D:1tc: I '7/13jlot~
tlcrnro.I 13.\l:irl 9
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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Attachment A- Criteria, Methods of Calculations and Fleet Calculations
The five ERC qualifying criteria are being met in the generation of these ERCs:
•
Real Each of the CNG trucks are designed to operate solely on natural gas. There is extensive
evidence, including engine certification testing results, to show that these trucks emit less NOx on a per
mile basis that their diesel counter parts. In quantifying the ERCs, actual miles traveled in the
nonattainment area are combined with actual emissions rates using standardize EPA modeling methods
applicable to these operating conditions. While these new CNG trucks are replacing older diesel trucks
with much higher NOx emissions, to assure that the reductions are real, the analysis is based on the
emissions of the CNG trash truck in comparison to a new diesel trash truck of the same vintage.
•
Quantifiable As described In detail in this Appendix A, the emissions reduction resulting from
the voluntary replacement of diesel trash collection trucks with lower NOx emitting CNG trucks is being
quantified using the EPA MOVES3.01, reflecting the miles traveled by the CNG trucks within the
nonattainment area. The model has been adjusted to reflect actual use patterns of the Waste
Management trash trucks and the difference in emissions between diesel and CNG in the year each CNG
truck was or will be placed into service.
•
Surplus The conversion to CNG trash truck fleets is being carried out on a voluntary basis. It is
not being done to comply with any current or anticipated regulatory requirement. We understand that
trash truck is the region appear as diesel powered In the Regional Ozone Modeling over the last decade
Including the latest (2017) Reglonal emissions inventory.
•
Permanent Waste Management is proposing to make these reductions pe'rmanent by keeping
these CNG trucks in service in the nonattalnment area and replacing them with CNG trucks or trucks
with equal or lower NOx emissions whenever one is removed from service. Proposed permit conditions
that would be added to the air permit of the Fleet location, reflecting this commitment, are presented in
Appendix B.
•
Enforceable The Fleet requirements will be added to existing minor source air permits issued
by the Maricopa County Air Quality Department. The conditions of these air permits are federally
enforceable. Waste Management will be requesting permit conditions in each of these permits that will
make the continuing use of these CNG trucks or replacement trucks with equal or lower NOx emissions
in the nonattainment area. See Appendix B. This will make the action that Waste Management has
taken to create these ERCs federally enforceable.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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DRAFT
The methods of calculations for the ERCs are:
Waste Management currently operates 225 refuse trucks powered by compressed natural gas
(CNG) engines in the greater Phoenix area that collect waste and deliver it to transfer stations.
The fleets are referred to as White Tank, San Tan, North Phoenix and Elwood. These CNG
vehicles are powered by U.S. EPA certified 2011to2020 model-year Cummins 8.9-liter engines.
The model-year 2011 to 2015 engines were certified by Cummins to the 0.2 g/bhp-hr NOx
standard that applies to 2010 and later model-year vehicles while the 2016 and later model-
year engines were certified by Cummins to family NOx emissions limits (FELs) of 0.02 g/bhp-hr.
The MERC calculation methodology is based on a comparison of the CNG refuse truck emissions
to the emissions of a diesel refuse truck of the same model year. A credit calculation is
performed for each CNG vehicle based the vehicle's lifetime average annual mileage reported
by Waste Management and the differential in emissions NOx between the CNG vehicle and a
diesel-powered refuse truck with an engine of the same model-year, computed for calendar
year 2021 derived from EPA's MOVES3.01.
The emissions differential calculation begins with 2010 through 2020 model-year emission
factors (in units of grams of NOx per mile of operation) for diesel and CNG refuse trucks
obtained by running MOVES 3.01 configured for Maricopa County in calendar year 2021. Two
adjustments were made to the MOVES 3.01 emission factors. The first was made to account for
the fact that the engines in the 2016 and later Waste Management CNG vehicles were certified
to a family emissions level (FEL) of 0.02 g/bhp·hr for NOx which is 10 times lower than the
applicable emission standard of 0.20 g/bhp-hr which is assumed in MOVES3.01.1 Therefore,
CNG emission rates for 2016 to 2020 model-year vehicles were assumed to be one-tenth of the
comparable diesel emission rate.
The second adjustment was made to account for the actual load factors experienced by Waste
Management's CNG vehicles during routine operations which is not appropriately accounted
for in MOVES 3.01.2 More specifically, Waste Management collected engine load data using a
Cummins engine analyzer3 from three trucks operating on actual in-use refuse routes
representative of the three main types of refuse truck operation occurring in the Waste
Management: 1) residential, 2) roll-off, and 3) frontload. These load factors were determined
1 Based on a review of the MOVES3 documentation related to emission factors for heavy-duty CNG trucks, it is
clear that the MOVES emission factors are based on data from 2011 and 2014 model-year vehicles certified to the
0.20 g/bhp-hr standard which overestimates the actual emissions of the 2016 to 2020 model-year CNG trucks. See
"Exhaust Emission Rates for Heavy-Duty Onroad Vehicles in MOVES3", EPA-420-R-20-018, November 2020, page
197.
2 For example, the MOVES3.01 fuel consumption values for 2011to2020 model-year refuse trucks are only about
12% higher than for transit buses rather than the expected average of about 30%. See Alternative Fuels Data
Center: Maps and Data - Average Fuel Economy by Major Vehicle Category (energy.gov)
3 The analyzer is lap top based unit that directly reads engine performance, monitoring data and calculate
parameters including the engine load factor. Dave - can you provide the name of software and maybe a llnk to a
Cummins web page where it is described?
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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DRAFT
to be 40.5% for residential, 31.5% for roll-off, and 38% for front end loaders which are much
higher than the 20 to 25% load engines experience during certification emissions testing.•
Therefore the diesel and CNG emission rates from MOVES3.01 were scaled using the load
factors provided by Waste Management divided by the 25% value that is the upper bound of
the range reported from certification testing.
The final MERC calculation for each CNG vehicle involved multiplying the weighted average
annual milage of that type of vehicle by the emissions difference between the diesel and CNG
emission rates. For example, the MERC value for a 2015 residential refuse truck that travels
50,000 miles would be:
MERC (tons/year)= 50,000 miles/year* (4.20-1.40) grams NOx/mile • (40.5/25)
= 243,000 grams NOx/year = 0.27 tons NOx/year
Where 4.20 and 1.40 grams NOx/mile are the MOVES3 generated NOx emission factors for
2015 model-year diesel and CNG refuse trucks, respectively.
While the MERC value for a 2020 front end loader refuse truck traveling 50,000 miles a year
would be:
MERC (tons/year)= 50,000 miles/year* (2.84 - 0.284) grams NOx/mile * (38/25)
= 194,256 grams NOx/year = 0.21 tons NOx/year
Where 2.84 grams NOx/mile is the diesel emission factor and 0.284 the assumed natural gas
emission factor given engine certification to a 0.02 g/bhp-hr NOx FEL.
The annual emissions reductions associated with CNG use in the individual trucks are then
summed over all trucks to arrive at the total MERC value for the 225 trucks. This value is then
multiplied by 0.95 in order to account for actual CNG truck operation in the Phoenix non-
attainment area based on Information provided by Waste Management indicating that 5% of
their operation occurs outside the nonattainment area.
4 Transit Bus Load-Based Modal Emission Rate Model Development, EPA/600/R-07 /106, July 2007, page 3·2.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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Appendix B
Proposed Permit Conditions for the Use of CNG Trash Trucks by the Waste
Management Fleets in the Maricopa Nonattainment Area1
Waste Management (WM) will maintain and operate a minimum of 225 CNG fueled trash trucks,
serving the four Fleets in the greater Phoenix area. Any retired CNG truck will be replaced with
either a new CNG truck certified at 0.02 g/bhp-hr or lower NOx emitting trash truck fueled with CNG
or an alternative fuel, with the replacement truck counting towards this total.
WM will conduct periodic service on each CNG truck consistent with the manufacturer's
recommendations consisting of:
Applicable
Engine
Description of Service
-
ALL
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics, check
fuel filter for moisture
I
-
ALL
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth, includes gas leak detection system validation
12L Gas
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth. includes engine oil and lube filter replacement
12L Gas
Spark Plug and Ignition System Service
ALL
Specific Inspections related to CNG engines and fuel system,
Includes the service of the high pressure and low-pressure fuel
filters
!
9LGas
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth. Includes servicing high pressure and low-
pressure fuel filters, engine oil and filter replacement
9LGas
Spark Plug and Ignition System Service
ALL
Specific inspection related to Engine, Transmission, Axles, Body
and Hydraulics
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
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ALL
Specific CNG Engine and fuel system inspection items, Engine
valve lash inspection and adjustment service
ALL
Service of CNG Fuel Delivery and Leak Detection System
ALL
CNG Tanks and Fuel Delivery System Inspection by qualified
Inspector
ALL
Annual DOT Inspection, PMI Forms have grayed sections that
need to be filled out for this service
WM shall maintain the following records:
•
Inventory of the CNG trucks used by these four Fleets
•
Records of the maintenance of these vehicles
Additionally, we propose to keep records showing generally that the CNG trash trucks are being used
in a manner consistent with the derivation of the ERCs. Without an enforceable limit. This would be
keeping the following records:
•
As part of the inventory of the CNG trucks, annually provide a listing the route(s) for each
truck with an annotation of whether the route is or is not predominantly in the
nonattainment area.
This would include:
•
Annually, WM shall demonstrate that 95% or more of the routes use by their CNG trucks
were predominately in the nonattainment area.
•
If this figure is not met, WM will notify the MCAPD and explain why the usage was less than
expected, what actions WM is taking to ensure that CNG truck use is consistent with this
target, and the outlook for the coming year.
These conditions would be Inserted into the current air permits of each of the four fleets using the CNG trucks for trash
collection.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
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Refuse truck activity 2021 NOx emission factors (g/mi)
Model year
Gasoline
Diesel
CNG
1992
7.18
29.66
1993
8.17
29.79
1994
7.35
29.75
1995
7.19
28.02
1996
7.19
29.88
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8.25
29.91
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4.24
27.19
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4.24
21.32
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20.39
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20.43
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20.25
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1.50
10.74
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10.73
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1.45
10.75
2006
1.45
10.76
2007
1.56
7.52
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0.47
7.29
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7.47
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4.24
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4.20
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4.20
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4.09
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1.40
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1.40
1.40
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REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 32 of 73
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16
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 34 of 73
DRAFT
August 13, 2021
Daniel Czecholinski
Philip A. McNeely, R.G. Director
Phone: 602-506-6701
Email: Philip.McNeely@maricopa.gov
Maricopa.gov/AQ
C leanAirMakeMore.com
Air Quality Division Director
Arizona Department of Environmental Quality
1110 West Washington Street
PhoenL'{, Arizona 85007
RE:
Emissions Reduction Certification (ERC)
Waste Management of Arizona, Inc. (White Tank Transfer Station) - MCAQD Facility
F001646
Dear Mr. Czecholinski:
The Maricopa County Air Quality Department (MCAQD) has verified the credit and number of
tons of actual emissions that have been reduced by replacing diesel-fueled solid waste collection
trucks with CNG-fueled trucks based at the Waste Management White Tank Transfer Station
located at 18605 West McDowell Road in Goodyear, Arizona. In accordance with the Arizona
Administrative Code, the following actual emissions have been verified for use as certified emission
credits:
·
Nitrogen Oxides (NOx): 4.1 tons/year
Per Maricopa County Rule 204 §301 and AAC Rule 18-2-1205.A, the Control Officer may certify an
emission credit if the credit is verified and dete1mined by all of the following:
1. A reduction in actual emissions that occurred after August 17, 1999.
The facili!J has replaced 22 dieselji1eled solid waste collection tmcks with 22 CNGft1eled solid waste collection
trttcks. Actttal NOx emissions from CNG trttcks are 65 - 90% less than dieselji1eled tntcks depending on model
yet11:
2. A quantifiable reduction in actual emissions.
The applicant submitted calc11lations using EPA 's lvlotor Vehicle Emissions Simulator software (v3.01) to qt1a11tijj
emissions from both the old and new tmcks. Actual vehicle miles traveled ivere also provided to define the actttal
emissions. EmissioJI baseline from the diese!jiteled tr'lfcks has been calm lated over a SCJies of years (i.e., 2013-2021)
depending 011 when the adtta! conversion occmn:d.
3. A permanent reduction in actual emissions.
The tntcks removed from service mttst be disabled or moved outside of the Nfaricopa Cotm!J non-attainment area as
required in the site air quality permit P0008309. The permit also requires that tll!J f11t11re replacemmt qf tntcks
must be eqttal to or lower emitting than the tr11ck being replaced. These ei({ontJable permit co11ditio11s make the
emissio11 reductions permanent.
Return to Table of Contents
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 35 of 73
DRAFT
Daniel Czecholinski
Date: August 13, 2021
Page 2of 2
4. An enforceable reduction in actual emissions.
The air qualiry permit (i.e., P0008309) far the faci!iry indttdes pmvisio11s reqttiring ret11oval ef the dieseljired tr11cks
that JJJere replaced ry the CNGJired !nicks be ret11oved fmtn the lvlaricopa Comiry ozone non-attai11me11t area.
Additional conditions in the permit require monitoring and record keeping to ft11ther make the redttctions e1iforceable.
5. A surplus reduction in actual emissions occurring in addition to any other required emission
reduction.
The rype ef trucks that farmed the basisfar the et11issio11 credit have been listed in the 2017 Ozone Periodic Emission
Inventory (PEI) and previotts PEis c1s dieselfi1eled vehicles. These inventories are ttsed far regional planning ry the
J\1micopa Association qf Governme11ts. No et11issio11 red11dio11s were required at the source either thrrmgh pla1111i11g or
regulation that wo1t!d reduce the ce1tified credits. TherefOre, the !oJJJer emitting CNGJired tr11cks are st11p!t1s to the
inventory. Conseqttent!J, the table below is a smm11ary ef the emission credit calculation.
Pollutant
Baseline Emissions
Ongoing Emissions
Certified Credits
(tons/year)
(tons/year)
(tons/year)
NOx
4.6
0.5
4.1
Based on the information submitted by the source and verified as described above, the MCAQD
certifies emission reduction credits in the amount of 4.1 tons of NOx.
T his notification is being provided to the Arizona Department of Environmental Quality in the
event the applicant submits the certified ERCs for deposit in the Arizona Emissions Bank.
If you have any questions or need additional information, please contact Richard Sumner of my staff
at Richard.sumner@maricopa.gov or 602-506-1842.
l,Zj#u
Philip A. McNeely, RG
Director
Maricopa County Air Quality Department
Cc:
David Bearden, Waste Management of Arizona, Inc.
Attachments
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 36 of 73
DRAFT
Emission Reduction Credit
Evaluation
Source: Waste Management (White Tank Transfer Station)
Facility ID: F001646
Permit: P0008309
Date: August 11, 2021
Project Description: Replace diesel-powered solid waste collection trucks with CNG-powered trucks.
Baseline Emissions: CNG trucks were brought into the fleet over a number of years. Therefore, the baseline is the diesel truck that was
replaced by the CNG truck. For example, the NOx emission rate from the diesel truck was 6.32 g/mile and CNG truck #106190
emission rate put into service in 2018 is 0.63 g/mile. (Emission rates based on EPA MOVES 3.01.) The reduction is the difference
between the baseline diesel truck emission rate and the CNG truck emission rate. Credits are reduced by 2.5% to allow for
mileage outside of the non-attainment area. Annual mileage used in the calculation is 97.5% of actual average mileage for each
individual truck.
Sample Calculation (1 Truck): (6.32 g/mile - 0.63 g/mile) x 13,220 miles/year x 0.975 = 118,813 g/yr = 0.08 tons/year
Total NOx from the attached spreadsheet for 22 trucks= 4.1395 tons (uncorrected for outside non attainment area)
Total Creditable NOx (after correction)= 4.1395 tons (97.5/99.17)
Creditable NOx reduction= 4.1 tons
Prepared by Richard Sumner
August 11, 2021
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 37 of 73
DRAFT
Relurn completed form lo
Maricopa Counly Air Quollly Department
J800 1 lorlh Central Ave Suile I ·100. Phoen1~ AZ 85012
Phone: 602.506.60 I 0 Fa~. 602.372.0587
AQPermilsitmail.moricopo.gov
36001 101111 Central Ave. Suire I .100. Phoenix. AZ 85012 or 501 Mo1lh .1,1111 SI, Suile 200 Pnoeno~ AZ 85000.
Emission Reduction Credit Application
Fac11.11y Information
I. Facilirr Name:
Waste Management of :\rizona, lnc.
222 S. ~dill :\ve., Suite 333
2. FacilHJ Address:
Ctty:
Tempe
Stace: • .\rizona
Zip Code; 85281
.
3. Permit#:
040086/ F0016-16 (\'<'hite Tanks)a
'Ol\002..'7 /Foo\ r.115 { Sl\r.ii'Afl). ObC>~'{ 3S/f DC>Ol.Jl\ 3 { i)€A._ ~~'1' ')
Contact Information
I
-1. Is the facility information the same as the contact information?
YesO
No [8J
5. Contact Name: Dave BC'.uden
222 S. l\1111 Ave., Suite 333
6. Contact Address:
City:
Tempe
Stare:
Arizona
Zip Code: 85281
7. Pollutant (Complete a separate sheet for e:ich pollutant):
NOx
8. Date:
Jun 28, 2021
9. l.Jst of 1hc equipment/process involved with 1he emission reduction:
Solid Waste Collection Trucks converted from diesel fuel to compressed natural gas
, ,\dd a Rm1: IDclca: n Rw
10. Describe how the emission reduction will be :iccomphshed:
Waste Management has been converting the majority of their solid waste collection truck fleets in the Phoenb: area from dtescl fuel co
Compressed Natural Gas (CNG), and is appliing foe NOx Emissions Reducuon Credits (ERCs) from the voluntary conversion of trucks
from diesel to CNG oper.ition. TI1e trucks arc associated w11h four collection tleets operate at three transfer stauons m the non-
attainment area. Attachment A prO\·ides qualifying criteria, method of calculations and fleet calculanons which have been met in the
generation of these ERCs.
11. Estimated d:1te of emission reduction: various sec attachment:\
12. Describe how the reduction will be made permanent:
13. Baseline period (two calcnd:u years):
2020
2021
If this is not the most recent cwo calendar years, provide a detailed explanation of why the most recent years were not used.
11le requirements related to the ERCs will be included with permit modification for the transfer st;1tions \\'hite Tanks, Deer Valley and
San Tan. The proposed requirements relate to I) \'171! will continue to purchase CNG trucks or alternative trucks with at least or better
NOx emissions compared to the current Cummins Engine, 2) perform routine engine maintenance and 3) maint:un ar least 22 trucks
operating 95% or more of their time in 1he Non·attainmcnt .Arca.
14. Identify the method that is proposed to calculate the baseline crrussions and how that method is being used. (Examples: matcrinl
balance, performance test data, continuous monitor, emission factors, etc.)
Sec Attachment A - Criteria, ~lcthods of Calculations and Fleet Calculations
lkvlscJ 13Mnrl 9
l'agc 1 of'.!
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 38 of 73
DRAFT
'11':
•I
Maricopa County Afr Quality Oeportme1>i
33·-;f:
ii
; ;j .. I"
t 5. List the seasonal emission rate on a quactcdr basis from the operation/process rhat provxdcd the c-m1ss1on rcducuon.
Bnschnc \'car One
2010
l.) I:
l.)2:
l.)3:
l.)4
.~---·"~"--~
----~~
Baseline \\-ar T\\·o
2021
QI:
Q2:
Q3:
Q4:
16. Calculation of bj.Scltne cm1ss1ons 10 tons per rear;
.\ List nny emission factors \Vlfh their source (include units)'.
Sec .-\ttat:hrncnt :\
I 1\dd a Row IDclctc: a Ro"
B. List assumpuons made to perform the C\tlcuhluons:
Sec .-\trachmcnt ;\
C. Sho\v ~ample of c:i.kubtions m;-ide to Ycrtfv cm1~s1on reducnon:
~cc ;\ttachmcot A
D. Busehnc emission rate (tons per year):
3'-1, I '-l
E. Pro'l.1dc n List of documents attached to substantiate rhc Im.sis for the calculauons (e.g., safety data sheets, process records,
matenal use records, monttonng records, etc.).
Sec Attachment.-\
I i\dd a Row I Delete: a Row
f. Comments or addiuonal tnformauon:
l7. Do rou plan to register the CcctJficd credits In the • .-\nzona Emissions Bank administered by the o\rtzon;1 Department of
Enntonmcnrnl QuaU~· (. \DEQ)? [{]Yes
0No
If yes, there IS a registration fee of $200 parable to :-\.DEQ. For more
1nformauon about the Ar1zon:1 Em1ss1ons Bank please rc\'IC\\' .-\nzon:i. .-\dnun1strit1ve Code Title 18, Chapter 2, :\rude 12.
18. I cerufy that the statcn1cnts and 1nfonnation proYidcd herein arc true, accurate, and complete based on information and belief formed
after reasonable inquiry.
-
.
Signature of o\vncr or responsible offic:taL I µ " . /\ {{.,,, wl...
Type or print name and 1irlc : I
o~ ~ttrk
I
Date: I '711312.ot~
lk•v1sl'J IJ~larl 9
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 39 of 73
DRAFT
Attachment A - Criteria. Methods of Calculations and Fleet Calculations
The five ERC qualifying criteria are being met in the generation of these ERCs:
•
Real Each of the CNG trucks are designed to operate solely on natural gas. There is extensive
evidence, including engine certification testing results, to show that these trucks emit less NOx on a per
mile basis that their diesel counter parts. In quantifying the ERCs, actual miles traveled in the
nonattainment area are combined with actual emissions rates using standardize EPA modeling methods
applicable to these operating conditions. While these new CNG trucks are replacing older diesel trucks
with much higher NOx emissions, to assure that the reductions are real, the analysis is based on the
emissions of the CNG trash truck in comparison to a new diesel trash truck of the same vintage.
•
Quantifiable As described in detail in this Appendix A, the emissions reduction resulting from
the voluntary replacement of diesel trash collection trucks with lower NOx emitting CNG trucks is being
quantified using the EPA MOVES3.01, reflecting the miles traveled by the CNG trucks within the
nonattainment area. The model has been adjusted to reflect actual use patterns of the Waste
Management trash trucks and the difference in emissions between diesel and CNG in the year each CNG
truck was or will be placed into service.
•
Surplus The conversion to CNG trash truck fleets is being carried out on a voluntary basis. It is
not being done to comply with any current or anticipated regulatory requirement. We understand that
trash truck is the region appear as diesel powered In the Regional Ozone Modeling over the last decade
including the latest (2017) Regional emissions inventory.
•
Permanent Waste Management is proposing to make these reductions permanent by keeping
these CNG trucks in service in the nonattainment area and replacing them with CNG trucks or trucks
with equal or lower NOx emissions whenever one is removed from service. Proposed permit conditions
that would be added to the air permit of the Fleet location, reflecting this commitment, are presented in
Appendix 8.
•
Enforceable The Fleet requirements will be added to existing minor source air permits issued
by the Maricopa County Air Quality Department. The conditions of these air permits are federally
enforceable. Waste Management will be requesting permit conditions in each of these permits that will
make the continuing use of these CNG trucks or replacement trucks with equal or lower NOx emissions
in the nonattainment area. See Appendix 8. This will make the action that Waste Management has
taken to create these ER Cs federally enforceable.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 40 of 73
DRAFT
The methods of calculations for the ERCs are:
Waste Management currently operates 225 refuse trucks powered by compressed natural gas
(CNG) engines in the greater Phoenix area that collect waste and deliver it to transfer stations.
The fleets are referred to as White Tank, San Tan, North Phoenix and Elwood. These CNG
vehicles are powered by U.S. EPA certified 2011 to 2020 model-year Cummins 8.9·1iter engines.
The model-year 2011 to 2015 engines were certified by Cummins to the 0.2 g/bhp-hr NOx
standard that applies to 2010 and later model-year vehicles while the 2016 and later model-
year engines were certified by Cummins to family NOx emissions limits (FELs) of 0.02 g/bhp-hr.
The MERC calculation methodology is based on a comparison of the CNG refuse truck emissions
to the emissions of a diesel refuse truck of the same model year. A credit calculation is
performed for each CNG vehicle based the vehicle's lifetime average annual mileage reported
by Waste Management and the differential in emissions NOx between the CNG vehicle and a
diesel-powered refuse truck with an engine of the same model-year, computed for calendar
year 2021 derived from EPA's MOVES3.01.
The emissions differential calculation begins with 2010 through 2020 model-year emission
factors (in units of grams of NOx per mile of operation) for diesel and CNG refuse trucks
obtained by running MOVES 3.01 configured for Maricopa County in calendar year 2021. Two
adjustments were made to the MOVES 3.01 emission factors. The first was made to account for
the fact that the engines in the 2016 and later Waste Management CNG vehicles were certified
to a family emissions level (FEL) of 0.02 g/bhp-hr for NOx which is 10 times lower than the
applicable emission standard of 0.20 g/bhp-hr which is assumed in MOVES3.0l.1 Therefore,
CNG emission rates for 2016 to 2020 model-year vehicles were assumed to be one·tenth of the
comparable diesel emission rate.
The second adjustment was made to account for the actual load factors experienced by Waste
Management's CNG vehicles during routine operations which is not appropriately accounted
for in MOVES 3.01.2 More specifically, Waste Management collected engine load data using a
Cummins engine analyzer3 from three trucks operating on actual in-use refuse routes
representative of the three main types of refuse truck operation occurring in the Waste
Management: 1) residential, 2) roll-off, and 3) frontload. These load factors were determined
l Based on a review of the MOVES3 documentation related to emission factors for heavy-duty CNG trucks, it Is
clear that the MOVES emission factors are base.d on data from 2011 and 2014 model-year vehicles certified to the
0.20 g/bhp-hr standard which overestimates the actual emissions of the 2016 to 2020 model-year CNG trucks. See
"Exhaust Emission Rates for Heavy-Duty Onroad Vehicles In MOVES3", EPA-420-R-20-018, November 2020, page
197.
2 For example, the MOVES3.0l fuel consumption values for 2011 to 2020 model-year refuse trucks are only about
12% higher than for transit buses rather than the expected average of about 30%. See Alternative Fuels Data
Center: Maps and Data - Average Fuel Economy by Maier Vehicle Category (energy.gov)
3 The analyzer is lap top based unit that directly reads engine performance, monitoring data and calculate
parameters including the engine load factor. Dave - can you provide the name of so~ware and maybe a link to a
Cummins web page where it is described?
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 41 of 73
DRAFT
to be 40.5% for residential, 31.5% for roll-off, and 38% for front end loaders which are much
higher than the 20 to 25% load engines experience during certification emissions testing.'
Therefore the diesel and CNG emission rates from MOVES3.01 were scaled using the load
factors provided by Waste Management divided by the 25% value that is the upper bound of
the range reported from certification testing.
The final MERC calculation for each CNG vehicle involved multiplying the weighted average
annual milage of that type of vehicle by the emissions difference between the diesel and CNG
emission rates. For example, the MERC value for a 2015 residential refuse truck that travels
50,000 miles would be:
MERC (tons/year)= 50,000 miles/year• (4.20-1.40) grams NOx/mile • (40.5/25)
= 243,000 grams NOx/year = 0.27 tons NOx/year
Where 4.20 and 1.40 grams NOx/mile are the MOVES3 generated NOx emission factors for
2015 model-year diesel and CNG refuse trucks, respectively.
While the MERC value for a 2020 front end loader refuse truck traveling 50,000 miles a year
would be:
MERC (tons/year)= 50,000 miles/year* (2.84-0.284) grams NOx/mile * (38/25)
= 194,256 grams NOx/year = 0.21 tons NOx/year
Where 2.84 grams NOx/mile is the diesel emission factor and 0.284 the assumed natural gas
emission factor given engine certification to a 0.02 g/bhp-hr NOx FEL.
The annual emissions reductions associated with CNG use in the individual trucks are then
summed over all trucks to arrive at the total MERC value for the 225 trucks. This value is then
multiplied by 0.95 in order to account for actual CNG truck operation in the Phoenix non-
attainment area based on Information provided by Waste Management indicating that 5% of
their operation occurs outside the nonattainment area.
4 Transit Bus load-Based Modal Emission Rate Model Development, EPA/600/R·07 /106, July 2007, page 3-2.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 42 of 73
DRAFT
Appendix B
Proposed Permit Conditions for the Use of CNG Trash Trucks by the Waste
Management Fleets in the Maricopa Nonattainment Area1
Waste Management !WM) will maintain and operate a minimum of 225 CNG fueled trash trucks,
serving the four Fleets in the greater Phoenix area. Any retired CNG truck will be replaced with
either a new CNG truck certified at 0.02 g/bhp-hr or lower NOx emitting trash truck fueled with CNG
or an alternative fuel, with the replacement truck counting towards this total.
WM will conduct periodic service on each CNG truck consistent with the manufacturer's
recommendations consisting of:
Applicable
Engine
Description of Service
-
ALL
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics, check
fuel filter for moisture
-
l
ALL
Specific inspection related to Cab, Engine, Transmission, Fuel
l
System, Steering System and Axles, Body and Hydraulics but
more in-depth, includes gas leak detection system validation
12L Gas
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth. includes engine oil and lube filter replacement
12L Gas
Spark Plug and Ignition System Service
ALL
Specific Inspections related to CNG engines and fuel system,
includes the service of the high pressure and low-pressure fuel
filters
[
9LGas
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth. Includes servicing high pressure and low-
pressure fuel filters, engine oil and filter replacement
9LGas
Spark Plug and Ignition System Service
-
ALL
Specific inspection related to Engine, Transmission, Axles, Body
and Hydraulics
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 43 of 73
DRAFT
ALL
Specific CNG Engine and fuel system inspection items, Engine
valve lash inspection and adjustment service
ALL
Service of CNG Fuel Delivery and Leak Detection System
ALL
CNG Tanks and Fuel Delivery System Inspection by qualified
Inspector
ALL
Annual DOT Inspection, PMI Forms have grayed sections that
need to be filled out for this service
WM shall maintain the following records:
•
Inventory of the CNG trucks used by these four Fleets
•
Records of the maintenance of these vehicles
Additionally, we propose to keep records showing generally that the CNG trash trucks are being used
in a manner consistent with the derivation of the ERCs. Without an enforceable limit. This would be
keeping the following records:
•
As part of the inventory of the CNG trucks, annually provide a listing the route(s) for each
truck with an annotation of whether the route is or is not predominantly in the
nonattainment area.
This would include:
•
Annually, WM shall demonstrate that 95% or more of the routes use by their CNG trucks
were predominately in the nonattainment area.
•
If this figure is not met, WM will notify the MCAPD and explain why the usage was less than
expected, what actions WM is taking to ensure that CNG truck use is consistent with this
target, and the outlook for the coming year.
'These conditions would be inserted Into the current air permits of each of the four fleets using the CNG trucks for trash
collection.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 44 of 73
DRAFT
Refuse truck activity 2021 NOx emission factors (g/mi)
Model year
Gasoline
Diesel
CNG
1992
7.18
29.66
1993
8.17
29.79
1994
7.35
29.75
1995
7.19
28.02
1996
7.19
29.88
1997
8.25
29.91
1998
4.24
27.19
1999
4.24
21.32
2000
20.39
2001
20.43
2002
20.25
2003
1.50
10.74
2004
10.73
2005
1.45
10.75
2006
1.45
10.76
2007
1.56
7.52
2008
0.47
7.29
2009
0.47
7.47
2010
5.88
2011
5.16
2012
5.27
2013
0.32
4.24
2014
4.20
2015
4.20
2016
4.09
2017
3.90
2018
2.84
2019
2.84
2020
2.84
2021
2.84
0.02CNG
8.30
8.30
8.30
1.40
1.40
1.40
1.40
1.40
1.40
0.93
0.93
0.93
0.93
0.93
0.93
. I
Total Credits
Total Vehicles
average mileage residential
average mileage roll off
average mileage front load
34.14 tons
225.00
18068
29577
44463
0.41
CNG emissions rates for vehicles certified to O. 02 g/bhp-hr
0.39
FEL are assumed to be 10% of same model-year diesel
0.28
emission rates
0.28
0.28
0.28
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 45 of 73
DRAFT
106189
106190
211939
214010
214011
214012
214418
214420
214668
4lS982
416403
416404
416S99
416600
4l706S
417068
4l76ll
417612
417613
41761S
Vehicles
wH11e
09/20/2018
40.S
01/02/2019
40.S
02104/2019
40.S
U/12/2018
31.S
03/18/2015
31.S
ll/26/2018
31.S
ll/30/2018
31.S
12/18/2018
31.S
09/06/2019
31.S
09/16/2019
31.S
01/17/2020
38.0
10/0S/2018
38.0
01/10/2019
38.0
01/1512019
38.0
06/24/2019
38.0
06/10/2019
38.0
09/23/2019
38.0
10/01/2019
38.0
06/22/2020
38.0
06/26/2020
38.0
06/22/2020
38.0
06/22/2020
22
35
23
21
26
82
49
Sl
Sl
S7
SB
68
30
23
2S
28
14
21
34
3S
27
56
60
Recent'
l\llileag•
Reaml
ll8t9 o1
Hours
ill
Diii& at a.- Milews•
RecentHours ~
Service
~
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
5,764
4,610
4,494
4,334
17,187
6,378
6,806
6,Sl9
4,958
S,010
3,896
7,338
8,71S
6,809
5,646
S,157
3,730
3,706
2,254
2,114
2,277
2,343
Sll
408
437
S09
2,211
l ,767
1,851
1,813
1,884
l,810
l,974
573
432
439
513
723
3SO
364
641
707
l,06S
1,178
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
04/28/2021
S0,095
3S,215
3S,S71
33,03S
203,339
90,829
93,874
91A71
55,043
61,839
56,219
153,898
152,698
149,911
ll8,68S
117,710
81,198
68,577
43,978
44,S61
42,050
50,559
951.0
847.0
814.0
898.0
2233.0
884.0
880.0
862.0
600.0
590.0
467.0
936.0
839.0
834.0
674.0
688.0
S83.0
575.0
310.0
306.0
310.0
310.0
2.32
2.23
2.46
6.12
2.42
2.41
2.36
1.64
1.62
1.28
2.56
2.30
2.28
l.85
1.88
l.60
l.S8
0.8S
0.84
0.85
0.8S
CUMMINS ISLG
1977
14,999 CUMMINS l9N
2006
15,754 CUMMINS l9N
1751
13,220 CUMMINS l9N
2796
32,876 CUMMINS ISLG
2613
36,773 CUMMINS ISLG
2802
38,169 CUMMINS ISLG
2739
37,964 CUMMINS ISLG
2981
32,338 CUMMINS l9N
3064
37,137 CUMMINS l9N
2992
42,397 CUMMINS l9N
28SO
S9,790 CUMMINS ISLG
3781
66,242 CUMMINS l9N
2969
65,416 CUMMINS l9N
3042
63,995 CUMMINS L9N
2728
62,064 CUMMINS l9N
2322
50,617 CUMMINS l9N
2331
43,300 CUMMINS l9N
2613
Sl,026 CUMMINS l9N
2489
52,310 CUMMINS l9N
2615
48,257 CUMMINS L9N
2688
S8,142 CUMMINS L9N
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
2017
2018
2018
2017
2014
2017
2017
2017
2018
2018
2019
2017
2018
2018
2018
2018
2018
2018
2019
2019
2019
2019
CNG
NOx
Diesel
(g/ mile
NOx
(g/mile)
0.63~
0.46~
0.46~
0.63 _.§B_
1.76~
0.49~
0.49~
0.49~
0.36~
0.36~
0.36~
0.59~
0.43~
0.43~
0.43~
0.43~
0 .43~
0.43 ~
0 .43~
0.43~
0.43~
0.43~
Total
Annual NOx Truck Route Percentage
Non-
EmissionsR within Non- within Non·
Attainm
eduction
attainment attainment
ent Area
(tons)
Area
Area
Miles
0.12 Yes
100%
19031
0.07 Yes
100%
14999
0.07 Yes
100%
15754
0.08 Yes
0.13 Yes
0.18 Yes
0.19 Yes
0.18 Yes
0.11 Yes
0.1.3 Yes
0.15 Yes
0.35 Yes
0.28 Yes
0.28 Yes
0.27 Yes
0.27 Yes
0.22 Yes
0.19 Yes
0.22 Yes
0.22 Yes
0.21 Yes
0.25 Yes
4.139S
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
lOO"h
100%
100".<
100".<
85%
100"-'
100%
Total NAA =
Tota! Miles =
% fn NAA=
13220
32876
36773
38169
37964
32338
37137
42397
S9790
66242
6S4l6
63995
62064
S06l7
43300
Sl026
44486
48257
58142
933994
941818
99.17%
average an
Residential
19,031
14,999
15,7S4
13,220
0
0
0
lS,751
Roll off
0
0
32,876
36,773
38,169
37,964
32,338
37,137
42,397
0
Front
Load
0
59,790
66,242
6S,416
63,995
62,064
50,617
43,300
Sl,026
44,486
48,2S7
58,142
36,808
5S,758
7
11
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 46 of 73
DRAFT
August 13, 2021
Daniel Czecholinski
Philip A. McNeely, R.G . Director
Phone: 602-506-6701
Email: Phllip.Mc Neely@maricopa.gov
Maricopa.gov/AG
CleanAirMakeMore.com
Air Quality Division Director
Arizona Department of Envirorunental Quality
1110 West Washington Street
Phoenix, Arizona 85007
RE:
Emissions Reduction Certification (ERC)
Waste Management of Arizona, Inc. (Deer Valley Transfer Station) - MCAQD Facility
F000443
Dear Mr. Czecholinski:
The Maricopa County Air Quality Department (MCAQD) has verified the credit and number of
tons of actual emissions that have been reduced by replacing diesel-fueled solid waste collection
trncks with CNG-fueled trucks based at the Waste Management Deer Valley Transfer Station
located at 2120 West Adobe Drive in Phoenix, Arizona. In accordance with the Arizona
Administrative Code, the following actual emissions have been verified for use as certified emission
credits:
Nitrogen Oxides (NOx): 11.2 tons/year
Per Ma1-icopa County Rule 204 §301 and AAC Rule 18-2-1205.A, the Control Officer may certify an
emission credit if the credit is verified and determined by all of the following:
1. A reduction in actual emissions that occurred after August 17, 1999.
The facili!J has replaced 74 diesel-ji1eled solid JJJaste collection tr'llcks with 74 CNG-ji1eled solid waste collection
tmcks. Actt1al NOx emissions from CNG tr11cks are 65 - 90% less than diesel-fi1eled tn1cks depending on model
yem:
2. A quantifiable reduction in actual emissions.
.
The applicant st1bmitted calct1lations using EPA 's Motor Vehicle Emissions Simulator sojtJJJare (v3.01) to qt1antify
emissiom from both the old and ne1JJ tn1cks. Actual vehicle miles traveled were also provided to define the actual
emissions. Emissio11 baseline from the diesel-fi1eled tmcks has been calculated over a series of years (i.e., 2013-2021)
depending on when the act11al conversion occt11red.
3. A permanent reduction in actual emissions.
The trncks removed from service mt1st be disabled or moved outside qf the Mmicopa Coim!J non-attainment area as
required in the site air q11ali!J permit P0008316. The permit also reqttires that mry fitt11re replacement of tntcks
mttst be eqt1al to or loJJJer emitting than the trttck being replaced These enforceable pe1mit conditions make the
emission reductions permanent.
Return to Table of Contents
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 47 of 73
DRAFT
Daniel Czecholinski
Date: August 13, 2021
Page 2of 2
4. An enforceable reduction in actual emissions.
The air q11ali!J permit (i.e., P0008316) for the jacili!J inclttdes provisions reqttiting removal of the diesel-fired tmcks
that were replaced ry the CNG-jired trt1cks be removed from the Jvlaricopa Cotmry ozone non-attainment area.
Additional co11ditions in the permit require monitoting and record keeping to flnther make the redttctions enforceable.
5. A sutplus reduction in actual emissions occurring in addition to any other required emission
reduction.
The type of trt1cks that formed the basis for the emissio11 credit have been listed i11 the 2017 Ozone Pe1iodic Emission
Inventory (PEI) and previotts PEis as dieselfueled vehicles. These invent01ies are ttsed for regional planning ry the
Mmicopa Association of Governments. No emission reductions JJJ~t-e 1-eqt1i1-ed at the sottrce either through planning or
1-egtt!ation that wottld mlttce the cettified mdits. Therefot-e, the lower emitting CNG-ji1-ed tr11cks m-e smplt1s to the
inventory. Conseqttent!J, the table helo1JJ is a summary of the emission mdit calcttlation.
Pollutant
Baseline Emissions
Ongoing Emissions
Certified Credits
(tons/year)
(tons/year)
(tons/year)
NOx
15.2
4.0
11.2
Based on the information submitted by the source and verified as described above, the MCAQD
certifies emission reduction credits in the amount of 11.2 tons of NOx.
This notification is being provided to the Arizona Department of Environmental Quality in the
event the applicant submits the certified ERCs for deposit in the Arizona Emissions Bank.
If you have any questions or need additional information, please contact Richard Sumner of my staff
at Richard.sumner@maricopa.gov or 602-506-1842.
Sincerely,
~c!i~G~
Director
Maricopa County Air Quality Department
Cc:
David Bearden, Waste Management of Arizona, Inc.
Attachments
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 48 of 73
DRAFT
Emission Reduction Credit
Evaluation
Source: Waste Management (Deer Valley Transfer Station)
Facility ID: F000443
Permit: P0008316
Date: August 11, 2021
Project Description: Replace diesel-powered solid waste collection trucks with CNG-powered trucks.
Baseline Emissions: CNG trucks were brought into the fleet over a number of years. Therefore, the baseline is the diesel truck that was
replaced by the CNG truck. For example, the NOx emission rate from the diesel truck was 5.29 g/mile and CNG truck #212441
emission rate put into service in 2016 is 1.76 g/mile. (Emission rates based on EPA MOVES 3.01.) The reduction is the difference
between the baseline diesel truck emission rate and the CNG truck emission rate. Credits are reduced by 2.5% to allow for
mileage outside of the non-attainment area. Annual mileage used in the calculation is 97.5% of actual average mileage for each
individual truck. The North Yard Fleet is associated with the Deer Valley Transfer Station.
Example Calculation (1 Truck): (5.29 g/mile - 1.76 g/mile) x 20,506 miles/year x 0.975 = 69,028 g/yr = 0.078 tons/year
Total NOx from the attached spreadsheet for 74 trucks= 11.5167 tons (uncorrected for outside non attainment area)
Total Creditable NOx (after correction)= 11.5167 tons (97.5/99.87)
Creditable NOx reduction= 11.2 tons
Prepared by Richard Sumner
August 11, 2021
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 49 of 73
DRAFT
Return completed form lo
Motlcopo Counly Air Quollly Department
3800 r'lotlh Cenlrot Ave Suite 1400. Phoenix
Phone: 602.506.6010 Fm. 602.372.0587
AQPermits ii moil.moricoµo.gov
3800 Morlh Cenlrol Ave. Suire 1.100. Phoe ni~. AZ 85012 or 501 Morlh ~4th SI. Suile 200 Phoe ni~ AZ 85008.
Emission Reduction Credit Application
Faciltt)' Information
1. Facilirr Name:
\X1aste !ll:magcmcnt of Arizona, Inc.
222 S. l\lill .-\vc., Swtc 333
2. Facility Address:
City;
Tempe
Sta tc: .-\rizona
Zip Code: 85281
3. Permit#:
040086/FOO 16-16 (\Vhitc Tnnks)GI 01.\002.17 /Foo\ C.115 ( <;;11 .. ri"'Atl) • 0tit>~4 3B/f DC>Ol1Y 3 { De.:il. v'kl.l:'.-V)
Contact Information
.
I
4. Is the facility information the same as the conmct information?
YesO
No 18]
5. Contacr Name: Dave: Bearden
222 S. l\1111 .-\ ve., Suuc 333
6. Conrnct .-\cldrcss:
City:
Tempe
State::
Ariwna
Zip Code: 85281
7. Pollutant (Complete a separate sheet for each pollutant):
NOx
8. Date:
Jun 28, 2021
9. List o f the equipment/process involved with the emission rcduc1ion:
Solid \Vnste Collection Trucks converted from diesel fuel to compressed natuml gas
I Add ~ Rnw I
Dclctc n RD\I
10. Describe how the emission reduction will be accomplished:
Wash: .l\l:magc:mc:nr has bc:c:n converting the majority of their solid waste: collection truck Oeets in the Phocnix arca from diesel fuel to
Compressed Narum! G:is (CNG), :ind is appl)i ng foe NOx Emissions Reducuon Credits (ERCs) from the voluntarr conversion o f trucks
from diesel to CNG oper-.1.tion. The trucks ace associated with four collccrion fleets operate nt three transfer stauons m the no n-
arrainment area. Attachment A pro\ides qualifying criteria, method of calcul:111ons and fleet calculations which have been met in the
generation of these ERCs.
11. Estimated date of emission reduction: vnrious sec attachment :\
12. Describe how the reduction will be made pc:cmancnt:
13. Baseline period (two calendar yeats):
2020
2021
If this is not the most recent rwo calendat years, provide a detailed explanation of why the most recent years were not used.
The requirements related to the ERCs will be included with permit modification for the transfer st;itions White Tanks, Deer Vallc:y and
San Tan. The proposed requirements relate to 1) \'\11\[ will continue to purchase CNG trucks or alternative trucks with at least o r better
NO.x emissions compared to the current Cummins Engine, 2) perform routine engine maintenance and 3) maintain :ir lc01st 22 trucks
operating 95% or more o f their rime in the Non·:llt:tlnmcnt Area.
14. Identify the method 1h:1t is proposed to calculate the baseline emissions and how that method is being used. (Examples: material
balance, perfocmance test data, continuous monitor, emission factors, etc.)
Sec Attachment A - Criteria, Methods of Calculations and Fleet Calculations
Rcvlml 13Marl9
Page l of 2
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 50 of 73
DRAFT
l'j t
f ·l....
Maricopa County Air Quality Oepartme 11t
3il ·c
.~ 1· JI
f "•. n
o\
I• J
~
( ' ;:; ._.,._ =--, .JI
t_.
it.Jo
15. Lisr the seasonal emission rate on a quarter!}' basis from the operation/ process that provided the em1ss1on reduction.
Bnschnc Year One
'.!020
(.,21:
Q2:
Q3:
Q4:
Baschne Yl-ar T\\'O
2021
QI:
Q1:
Q3:
Q4·
16. Calculation of baseltnc emissions m tons per )·car:
,-\ List :mr emission factors with their source (include umts):
Sec .-\uachmcnt _-\
I Add 3 Row IDclctc a Ro\L
B, List assumptions made to perform the c,1lcubuons:
Sec ;\trachmcnt .-\
C. Show snmplc of c:1lcubt1ons made to ,·cnfv cm1ss1on rcducuon·
Sec :\ttachmcnt A
D . Baseline emission mtc (tons per year):
3Y,14
E. Provide n list of documents attnched to subsranrfate the basis for tin: calculanons (e.g., safety data sheets, proct:ss records,
matenal use records, monttonng rt:cords, etc.).
Sec .-\ttachmcnt .-\
I 1\dd a RolV I Delete 3 Row
F. Comments or :u.ld1uonal mformauon:
17. Do you plan to register the certified crcdas m the .-\nzona Em1ss1ons Bank admimstcred by the . .\rizona Department of
Enrnonmenral Quality (.\DEQ)? [{)Yes
0
No
If )'CS, there 1s a reg1str:1t1on fee of $'.!00 payable to .-\DEQ. For more
1nform:1uon about the :\rizona Em1ss1ons Bank please re,·1ew .-\nzona .-\dminismmve Code Title 18, Chap1cr 2, :\mcle 12.
18. l ecru!)· that the statements and mformation prm·idcd herein arc true, accurate, and complete based on mforrnaoon and bchcf formed
afrcr m1sonable inquiry.
-
Signature of owner or rcspons1blc official: I ~~llAlJ....
I
Trpt: or pnnc n:ime and uric : I
o~ ~(tf~
I Dare: I rt'j13llot~
lk l'i~cJ 13.\larl 9
l'~~o.: '.! uf '.!
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 51 of 73
DRAFT
Attachment A - Criteria, Methods of Calculations and Fleet Calculations
The five ERC qualifying criteria are being met in the generation of these ERCs:
•
Real Each of the CNG trucks are designed to operate solely on natural gas. There is extensive
evidence, including engine certification testing results, to show that these trucks emit less NOx on a per
mile basis that their diesel counter parts. In quantifying the ERCs, actual miles traveled in the
nonattalnment area are combined with actual emissions rates using standardize EPA modeling methods
applicable to these operating conditions. While these new CNG trucks are replacing older diesel trucks
with much higher NOx emissions, to assure that the reductions are real, the analysis is based on the
emissions of the CNG trash truck in comparison to a new diesel trash truck of the same vintage.
•
Quantifiable As described in detail in this Appendix A, the emissions reduction resulting from
the voluntary replacement of diesel trash collection trucks with lower NOx emitting CNG trucks is being
quantified using the EPA MOVES3.01, reflecting the miles traveled by the CNG trucks within the
nonattainment area. The model has been adjusted to reflect actual use patterns of the Waste
Management trash trucks and the difference in emissions between diesel and CNG in the year each CNG
truck was or will be placed into service.
•
Surplus The conversion to CNG trash truck fleets is being carried out on a voluntary basis. It is
not being done to comply with any current or anticipated regulatory requirement. We understand that
trash truck is the region appear as diesel powered in the Regional Ozone Modeling over the last decade
including the latest (2017) Regional emissions inventory.
•
Permanent Waste Management is proposing to make these reductions permanent by keeping
these CNG trucks in service in the nonattainment area and replacing them with CNG trucks or trucks
with equal or lower NOx emissions whenever one is removed from service. Proposed permit conditions
that would be added to the air permit of the Fleet location, reflecting this commitment, are presented in
Appendix B.
•
Enforceable The Fleet requirements will be added to existing minor source air permits issued
by the Maricopa County Air Quality Department. The conditions of these air permits are federally
enforceable. Waste Management will be requesting permit conditions in each of these permits that will
make the continuing use of these CNG trucks or replacement trucks with equal or lower NOx emissions
in the nonattainment area. See Appendix B. This will make the action that Waste Management has
taken to create these ERCs federally enforceable.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 52 of 73
DRAFT
The methods of calculations for the ERCs are:
Waste Management currently operates 225 refuse trucks powered by compressed natural gas
(CNG) engines in the greater Phoenix area that collect waste and deliver it to transfer stations.
The fleets are referred to as White Tank, San Tan, North Phoenix and Elwood. These CNG
vehicles are powered by U.S. EPA certified 2011 to 2020 model-year Cummins 8.9-llter engines.
The model-year 2011 to 2015 engines were certified by Cummins to the 0.2 g/bhp-hr NOx
standard that applies to 2010 and later model-year vehicles while the 2016 and later model-
year engines were certified by Cummins to family NOx emissions limits (FELs) of 0.02 g/bhp-hr.
The MERC calculation methodology is based on a comparison of the CNG refuse truck emissions
to the emissions of a diesel refuse truck of the same model year. A credit calculation is
performed for each CNG vehicle based the vehicle's lifetime average annual mileage reported
by Waste Management and the differential in emissions NOx between the CNG vehicle and a
diesel-powered refuse truck with an engine of the same model-year, computed for calendar
year 2021 derived from EPA's MOVES3.0l.
The emissions differential calculation begins with 2010 through 2020 model-year emission
factors (in units of grams of NOx per mile of operation) for diesel and CNG refuse trucks
obtained by running MOVES 3.01 configured for Maricopa County in calendar year 2021. Two
adjustments were made to the MOVES 3.01 emission factors. The first was made to account for
the fact that the engines in the 2016 and later Waste Management CNG vehicles were certified
to a family emissions level (FEL) of 0.02 g/bhp-hr for NOx which is 10 times lower than the
applicable emission standard of 0.20 g/bhp-hr which is assumed In MOVES3.01.1 Therefore,
CNG emission rates for 2016 to 2020 model-year vehicles were assumed to be one-tenth of the
comparable diesel emission rate.
The second adjustment was made to account for the actual load factors experienced by Waste
Management's CNG vehicles during routine operations which is not appropriately accounted
for in MOVES 3.01.2 More specifically, Waste Management collected engine load data using a
Cummins engine analyzer3 from three trucks operating on actual in-use refuse routes
representative of the three main types of refuse truck operation occurring in the Waste
Management: 1) residential, 2) roll-off, and 3) frontload. These load factors were determined
1 Based on a review of the MOVES3 documentation related to emission factors for heavy-duty CNG trucks, It Is
clear that the MOVES emission factors are based on data from 2011 and 2014 model-year vehicles certified to the
0.20 g/bhp-hr standard which overestimates the actual emissions of the 2016 to 2020 model-year CNG trucks. See
"Exhaust Emission Rates for Heavy-Duty Onroad Vehicles In MOVES3", EPA-420-R-20-018, November 2020, page
197.
2 For example, the MOVES3.0l fuel consumption values for 2011 to 2020 model-year refuse trucks are only about
12% higher than for transit buses rather than the expected average of about 30%. See Alternative Fuels Data
Center: Maps and Data - Average Fuel Economy by Malor Vehicle Category (energy.gov)
3 The analyzer is lap top based unit that directly reads engine performance, monitoring data and calculate
parameters including the engine load factor. Dave - can you provide the name of software and maybe a link to a
Cummins web page where it is described?
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 53 of 73
DRAFT
to be 40.5% for residential, 31.5% for roll-off, and 38% for front end loaders which are much
higher than the 20 to 25% load engines experience during certification emissions testing.'
Therefore the diesel and CNG emission rates from MOVES3.01 were scaled using the load
factors provided by Waste Management divided by the 25% value that is the upper bound of
the range reported from certification testing.
The final MERC calculation for each CNG vehicle involved multiplying the· weighted average
annual miiage of that type of vehicle by the emissions difference between the diesel and CNG
emission rates. For example, the MERC value for a 2015 residential refuse truck that travels
50,000 miles would be:
MERC (tons/year)= 50,000 miles/year• (4.20-1.40) grams NOx/mile * (40.5/25)
= 243,000 grams NOx/year = 0.27 tons NOx/year
Where 4.20 and 1.40 grams NOx/mile are the MOVES3 generated NOx emission factors for
2015 model-year diesel and CNG refuse trucks, respectively.
While the MERC value for a 2020 front end loader refuse truck traveling 50,000 miles a year
would be:
MERC (tons/year) = 50,000 miles/year • (2.84- 0.284) grams NOx/mile * (38/25)
= 194,256 grams NOx/year = 0.21 tons NOx/year
Where 2.84 grams NOx/mile is the diesel emission factor and 0.284 the assumed natural gas
emission factor given engine certification to a 0.02 g/bhp-hr NOx FEL.
The annual emissions reductions associated with CNG use in the individual trucks are then
summed over all trucks to arrive at the total MERC value for the 225 trucks. This value is then
multiplied by 0.95 in order to account for actual CNG truck operation in the Phoenix non-
attainment area based on information provided by Waste Management indicating that 5% of
their operation occurs outside the nonattainment area.
4 Transit Bus Load-Bas.d Modal Emission Rate Model Development, EPA/600/R-07 /106, July 2007, page 3-2.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 54 of 73
DRAFT
Appendix B
Proposed Permit Conditions for the Use of CNG Trash Trucks by the Waste
Management Fleets in the Maricopa Nonattainment Area1
Waste Management !WM) will maintain and operate a minimum of 225 CNG fueled trash trucks,
serving the four Fleets in the greater Phoenix area. Any retired CNG truck will be replaced with
either a new CNG truck certified at 0.02 g/bhp-hr or lower NOx emitting trash truck fueled with CNG
or an alternative fuel, with the replacement truck counting towards this total.
WM will conduct periodic service on each CNG truck consistent with the manufacturer's
recommendations consisting of:
Applicable
Engine
Description of Service
-
ALL
Specific Inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics, check
fuel filter for moisture
"
I
ALL
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in"depth, includes gas leak detection system validation
12L Gas
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth. Includes engine oil and lube filter replacement
12L Gas
Spark Plug and Ignition System Service
ALL
Specific Inspections related to CNG engines and fuel system,
includes the service of the high pressure and low-pressure fuel
filters
9LGas
Specific inspection related to Cab, Engine, Transmission, Fuel
System, Steering System and Axles, Body and Hydraulics but
more in-depth. Includes servicing high pressure and low-
pressure fuel filters, engine oil and filter replacement
9LGas
Spark Plug and Ignition System Service
-· ALL
Specific inspection related to Engine, Transmission, Axles, Body
and Hydraulics
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 55 of 73
DRAFT
ALL
Specific CNG Engine and fuel system inspection items, Engine
valve lash inspection and adjustment service
ALL
Service of CNG Fuel Delivery and Leak Detection System
ALL
CNG Tanks and Fuel Delivery System Inspection by qualified
Inspector
ALL
Annual DOT Inspection, PMI Forms have grayed sections that
need to be filled out for this service
WM shall maintain the following records:
•
Inventory of the CNG trucks used by these four Fleets
•
Records of the maintenance of these vehicles
Additionally, we propose to keep records showing generally that the CNG trash trucks are being used
in a manner consistent with the derivation of the ERCs. Without an enforceable limit. This would be
keeping the following records:
•
As part of the inventory of the CNG trucks, annually provide a listing the route(s) for each
truck with an annotation of whether the route is or is not predominantly in the
nonattainment area.
This would include:
•
Annually, WM shall demonstrate that 95% or more of the routes use by their CNG trucks
were predominately in the nonattainment area.
•
If this figure is not met, WM will notify the MCAPD and explain why the usage was less than
expected, what actions WM is taking to ensure that CNG truck use is consistent with this
target, and the outlook for the coming year.
'These conditions would be inserted Into the current air permits of each of the four fleets using the CNG trucks for trash
collection.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 56 of 73
DRAFT
Refuse truck activity 2021 NOx emission factors (g/mi)
Model year
Gasoline
Diesel
CNG
1992
7.18
29.66
1993
8.17
29.79
1994
7.35
29.75
1995
7.19
28.02
1996
7.19
29.88
1997
8.25
29.91
1998
4.24
27.19
1999
4.24
21.32
2000
20.39
2001
20.43
2002
20.25
2003
1.50
10.74
2004
10.73
2005
1.45
10.75
2006
1.45
10.76
2007
1.56
7.52
2008
0.47
7.29
2009
0.47
7.47
2010
5.88
2011
5.16
2012
5.27
2013
0.32
4.24
2014
4.20
2015
4.20
2016
4.09
2017
3.90
2018
2.84
2019
2.84
2020
2.84
2021
2.84
0.02 CNG
8.30
8.30
8.30
1.40
1.40
1.40
1.40
1.40
1.40
0.93
0.93
0.93
0.93
0.93
0.93
Total Credits
Total Vehicles
average mileage residential
average mileage roll off
average mileage front load
34.14 tons
225.00
18068
29577
44463
0.41
CNG emissions rotes for vehicles certified to 0. 02 g/bhp-hr
0.39
FEL are assumed to be 10% of same model-year diesel
0.28
emission rates
0.28
0.28
0.28
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 57 of 73
DRAFT
104474
10C4?5
105290
105291
106100
106101
l5l050
211459
211465
2114!12
211493
211784
211785
211780
211781
211788
211189
211190
211916
211971
212219
212220
212;1.21
212222
2U437
212438
212439
212440
212441
212442
212940
212941
212942
2!-C013
21~14
214279
214280
2l44l3
21.C..:1.(
2.1.(.(:5
21«!6
214417
214419
21523.S
215239
215240
2154'4
215465
215466
3Dl15
36)115
414040
4l40i'l
414072
414083
414089
414371
414372
41073
414374
41A37S
414547
414653
414995
4149%
414997
414998
415'95
415996
416601
415602
416603
411066
417067
ToUI
40,5 12/18/2013
40.S 1.l/18/2013
40.5 11/24/2015
40.5 U/OS/2015
40.5 11/0l/2018
40.5 09/24/2018
40.5 0!/15/2018
31.5 12/18/2013
31.5 05/13/2013
31..S 05/13/2013
31..S OC/22/2013
31.5 01/01/201.5
]l.5 01/10/2015
31..S 11/10/2014
31.5 0 1/01/2015
31..5 02/01/2015
31..S 02/01/2015
ll.5 02/01/2015
31.5 02/27/2015
31.5 01/04/2015
31.5 06/24/2015
31.5 10/15/2015
31.S 09/10/2015
31.S
09/~/2015
31.S 11/02/2015
lt.S 12/04/201S
"31.5 12/23/2015
31.S 01/04/2016
31.S 01/08/2016
31.5 OlJU/2016
.u.5 ovao(2011
31.5 02/09/2017
31.S 03/15/2017
31.5 02/04/2019
31.S 12/11/2018
n.S 01/2-4/2019
31.5 01/28/2019
31.5 07/01/201.9
31.5 08/09/2019
31.5 07/01/2019
31.S 07/15/201.9
ll.S 08/09/2019
ll.5 07/22/2019
ll.S 06/03/2020
:11.5 06/29/2020
31.S 06/lS/2020
ll.S 11/11/2020
31.5 12/30/2020
31.5 ll/11/2020
-40.S 03/15/2012
40.S 03/lS/2012
lS,0 12/lS/2013
38.0 ll/30/2013
38.C ll/12/20l3
38.0 12/10/2013
38.0 11/12/2013
38.0 03/13/2015
38,0 03/U/2015
38.0 03/09/2015
38.0 03/23/2015
38.0 03/13/2015
38.0 04/ll/2016
38.0 09/21/2015
.38.0 02/22/2016
.!8.0 03/28/2016
.33.0 03/01/2016
38.0 02/01/2016
38.0 08./.31/2018
38.0 09/l7/20t8
3M 04/26/2019
38.0 03/05/2019
38.0 04/11/2019
38.0 10/02/2019
38.0 11/0C/2019
11 05/13/2021
12 05/13/2021
66 05/13/202.l
&4
OS/13/2021
247
05/13/2021
45
05/13/2021
40 05/13/2021
71
05/1.3/2021
68 05/13/2021
70 OS/U/2021
78
05/13/2021
73
05/13/2021
124
OS/13/2021
66 05/13/2021
6l 05/13/2021
54
OS/13/2021
86 05/13/2021
64
05/13/2021
101
OS/13/2021
84
OS/lJ/2021
68
05/13/2021
55
OS/lJ/20lt
&3
OS/U/2021
SS
OS/U/2021
90
05/13/2021
61
05/13/2021
82
05/13/2021
Sl OS/ll/;i'.021
75
OS/U/2021
123
OS/U/2021
&9
05/11/2021
62
05/13/2021
57 05/13/2021
64
05/13/2021
99
05/13/202-1
63 05/U/2021
74
05/13/202l
49
05/13/2021
48
05/13/ 2021
so
05/13/2021
67
OS/13/2021
45
05/13/2021
S5
OS/13/2021
15
05/13/2021
49
05/13/2021
46
05/13/2021
46
05/1.3/2021
Sl
05/13/20l1
46
05/13/2021
29
05/U/2021
23
05/13/2021.
Sl
05/13/2021.
61
05/13/2021
16
OS/13/2021
21
05/13/2021
19
OS/13/2021
40
05/13/202l
33
OS/13/2021
29
05/13/2021
31
05/13/2021
34
05/13/2021
39
05/13(2021
35
05/13/2021
31
05/1.3/2021
35
05/13/2021
48
OS/13/2021
31
05/13/2021
38
05/13/2021
34
OS/13/2021
24
05/13/2021
u
05/13/1021
29
05/13/2021
21
05/lJ/2021
28
05/13/2021
15,433
14,650
12,744
12,467
5,5$8
S.605
6,391
19,320
19,2&7
20,007
19,650
17,1 21
l7,S20
17,311
16,840
17,996
16,866
17,464
17,346
16,207
13,920
14,896
14,828
15,119
lS,241
14,933
15,012
!4,120
1.:,290
13,~6
11,712
10.457
10,9:t0
5,600
6,616
5,567
6.232
4,093
4,591
4,6e.9
4,960
4,411
4,890
2.4U
2,411
2,261
1,011
m
l,081
6,828
8,283
16,059
18,500
19,244
19,024
16,586
U,264
13,741
12,960
13,741
13,860
12,287
14,101
14,659
12,0lS
11.876
13,598
5.nsi
S,93S
!i,1.517
4,533
4,445
3.040
U i16
2246 05/13/2021
2561 OS/13/2021
1804
05/13/2021
1382 05/13/2021
o OS/13/2021
0
OS/13/2021
1700 OS/13/2021
OS/13/2021
OS/13/2021
458
05/13/2021
0
05/13/2021
05/13/2021
05/13/2021
05/13/202J
05/13/2021
0
05/13/2021
0
05/11/2021
0
05/13/2021
OS/13/2021
05/13/2021
0
05/13/2021
1923
05/13/2021
0
OS/U/2021
2607 05/U/2021
1845 05/13/2021
2150 05/13/2021
2102
05/13/2021
1795 05/13/2021
1745
OS/13/2021
1795
05/13/2021
1822 05/13/2021
1705
05/13/2021
1711
05/13/2021
0
05/13/2021
136 OS/13/2021
0
05/13/2021
179
05/13/2021
0
05/13/2021
0
05/13/2021
O OS/13/2021
93S OS/13/2021
0
05/13/2021
0
OS/13/2021
4!)4
05/13/2021
400 05/13/2021
408 05/13/2021
508
05/13/2021
424
05/13/2021
395 05/19/2021
.:806 OS/13/2021
0
05/13/2021
05/13{2021
OS/13/2021
686 05/13/2021
2225 OS/13/2021
1S36 05/13/2021
0
OS/ll/2021
0
05/ 13/2021
0
05/13/2021
0
05/13/2021
0
OS/ 13/2021
1822 05/13/2021
4016 05/13/2021
1785 05/13/2021
1821
0<;/13/2021
1670 05/13/2021
1855 05/13/2021
1791
OS/13/2021
1946 05/13/2021
0
05/13/2021
05/13/2021
OS/13/2021
0
05/13/2021
Sl? 05/13/2021
186,606
178,345
121,255
149,148
58,205
65,117
64,on
325,5.llS
212.494
221,960
234,789
175,04S
220,973
210.227
189,119
220,131
206,561
230,994
173,863
16',839
194,561
164,705
llS,800
177,252
197,785
163,771
192,761
132,637
lll,410
158,881
111,643
145,518
142,173
65.692
52,530
66,323
79,1<1
45,767
38,455
60,859
49,284
52,225
67,473
27,278
35,224
15,041
15,062
12,401
16,754
65,142
87,537
332,208
367,190
191,171
335,3&4
333,061
266,443
299,186
271,242
291,585
252,096
24,,523
231,220
287,330
241,SOO
232,652
282,000
116.229
130,765
US,541
99,347
80,586
60,437
28.218
2701.0
2703.0
1997.0
1,86.0
924.0
962.0
1002.0
2703.0
2922.0
2922.0
2943.0
2324.0
2315.0
2346.0
2324.0
2293.0
n93.0
2293.0
2267.0
2321.0
2089.0
2037.0
2072.0
2052.0
201.9.0
1987.0
1968.0
l.956.0
1952.0
l.947.0
1564.0
1554.0
1520.0
829.0
878.0
S40.0
836.0
682.0
643.0
682.0
668.0
643.0
661.0
344.0
318.0
ll2.0
183.0
134.0
183.0
3146.0
3346.0
2703.0
2721.0
2739.0
2711.0
2739.0
22S3.0
22S3.0
22S7,0
2243.0
2:ZS3.0
18S8.o
2061.0
1907.0
1872.0
1899.0
192!.0
986.0
969.0
748,0
tco.o
163.0
589.0
556,0
7.41
1.41
5.41
5.44
2.53
""
2.7S
1.41
8.0l
8.01
.. ,.
6.37
6.34
6.43
6.37
·~·
6.28
6.28
~"
6.36
S.72
S.58 ....
5.52
5.53
5.44
5.39
5.36
5.35
5,33
4.28
4,26
4.16
2.27
2..:1
2.30
2.2'
1.87
l.16
1.87
l .83
l.76
l.81
0"4
0~1
0'1
0.50
0.37
0.50
9.17
9.17
7.41 ,,,
1.SO
1A3
1.50
6.17
6.17
6.18
6.15
6.11
5.09
5.6S
5.22
S.13
S.20
5.28
2.10
2.6S
2.05
2.19
2.1)9
1.61
""
2074
24,MS CUMMINS ISlG
1977
23,737 CUMMINS IStG
2317
21,833 CUMM1NSISlG
2280
27,066 CUMMINS 15lG
2098
22,992 CUMMINS ISLG
2110
24,707 CUMMINS ISLG
2313
22,720 CUMMINS ISLG
2599
44,095 CUMMINS 15LG
2398
26,544 CUMMINS ISlG
7490
27.669 CUMMINS 15lG
2427
2.9,119 CUMMINS ISLG
2678
27,649 CUMMINS ISlG
2743
34,840 CUMMI NS tslG
26.83
32,708 CUMMINS ISLG
2635
29,702 CUMMINS tsLG
2855
35,040 CUMMINS ISLG
2671
32,881 CUMMINS ISLG
2170
36,170 CUMMINS tsLG
2777
27,993 CUMMINS ISlG
2535
25,923 CUMMINS tSlG
2420
33,995 CUMMINS ISlG
2659
29,168 C\JMMINS ISt.G
2601
20,399 CUMMINS !stG
2680
31,065 CUMMINS ISlG
273:9
35,423 CUMMINS ISlG
2732
29,689 CUMMtNS !st.G
2780
35,361 CUMMINS ISl.G
2623
24,416 CUMMINS !51..G
26S8
20,506 CUMMINS JstG
2563
29,449 CUMMINS lSlG
2717
25,630 CUMMINS !SlG
2442
33,778 CUMMINS lstG
2611
33,729 CUMMINS !stG
2440
28.923 CUMMINS L!JN
2709
21, 781 CUMMINS !stG
2392
28,3 19 CUMMINS l9N
2689
l4,475 CUMMINS l9N
2164
24,494 CUMMINS l9N
2579
21,829 CUMM:NS L9N
2483
32,571 CUMMINS L9N
2674
26,418 CUMMINS l9N
2478
29,646 CUMMINS l9N
2670
37,258 CUMMINS l9N
2563
28,41.9 CUMMJN5 l9N
2711
l9,'J7l CUMMJNS t9N
2435
16,087 CUMMlN5 1.'JN
1925
29.028 CUMM1N5 l9N
1828
12,640 CUMMINS ~N
2064
32,629 CUMMINS 1.9N
742
6,582 CUMMJNS lSlG
901
9,554 CUMMlNS ISlG
216"2
44,860 CUMMINS lSlG
2473
49,256 CUMMINS tSlG
2562
S2,38l CUMMINS ISLG
2559
Sl.651 CUMMINS J51G
2208
44,179 CUMMINS lSl.G
2142
43,165 CUMMINS JSlG
2221
48,470 C\JMMINS ISlG
2091
43,865 CUMMINS ISlG
2231
47,449
CUMMINS JSLG
2240
40,841 C\JMMINS 15LG
2406
4!1,660 CU MM INS ISLG
2491
40,237 CUMMINS ISLG
2800
S4,653 CUMM INS ISLG
2340
46,732 CUM MINS ISLG
2273
44,396 CUMM INS ISLG
25&8
53,036 CUMMINS ISLG
2177
42,363 CUMM INS ISLG
2223
48,523 CUMM INS ISLG
2524
56,380 CUMM INS L9N
2063
4S,327 CUMMINS \.9N
21U
3S.SSO CUMM INS l9N
1811
37,1152 CUMMINS 1..9N
1042
18.185 CUMM INS l9N
'20
320
320
320
'20
l20
"°
"°
320
320
320
320
320
320
320
"°
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
320
"°
320
320
320
320
320
320
320
320
320
320
320
320
320
"°
320
320
320
320
320
320
320
320
320
"°
"°
320
320
l20
320
"°
320
320
320
320
320
"°
320
"°
320
320
310
TNCk
Annu.I
Route
Perccntag
NOx
wltl'iln
c within
Non·
CNG
Cle:t0l
Eml»lons Non-
Non·
Attalnmo
NOx
NOx
Reduction attalnmc ott.olnmon nt Aro•
RO$fdon
Front
h:i:/mll•) J..e!!!ill!l
(tons)
nt Area
t Arca
Mllll'S
II.Ill
RoUoff Loodor
2012
2.21 _____!.,ll.
0.17 Yes
100%
24895
24,895
O
O
20U
2.27 ~
0,16 Yl!S
100%
23'31
23,737
2014
2.27 ~
O.U Ye$
100%
218H
21,833
2014
2.21 ~
0.14 Yt>:i
100%
27066
27,066
2017
0.61 ~
0.14 Yes
100%
22992
22,992
2017
0.63 ~
0,15 Ye-.
100%
24707
24,707
2017
0.63 __..§:11.
0.14 y~
100%
22720
22,720
2012
l .77
6.64
0,24 y~
100%
44095
0
44,095
2012
1.17
6.64
0.14 Yrs
100%
26544
O
26.544
2012
1.77
6.64
0.15 Yrs
100%
27569
o
27,669
2012
1.71
6.64
0.16 Ye-s
100%
2.9119
29,119
2014
1.76
S.29
0.11 Yll'$
100%
21649
27.649
2014
1.76
5.29
0,1.; No
91%
31720
31,720
2013
l 17 ~
0.13 'fes
Hl0%
12708
32,708
2014
1.76~
0.12 Yts
100%
29702
29,702
2014
l.76~
0.14 Yll'I
100%
35040
35,040
2014
l.76~
0.13 YM
100'..4
32881
32.881
2014
1.75~
0.11; YM
100%
3&770
36,770
2014
1.76
S.29
0.11 Yes
10014
27993
0
27,993
2014
1.76
5.29
0.10 Yrs
100%
25923
0
25,923
2014
1.75~
0.13 Ye!$
100%
33995
O
33,995
2014
1.76~
0.11 YC$
100"..4
29168
29,168
2014
1.76~
0.08 Yn
100'..4
20399
20,399
2014
1.76~
0.12 Yrs
100%
310li5
0
31,065
2014
1.76 ___j,12..
0.14 y~
100'..4
35423
35,423
2014
l .76
5.29
O.l2 y~
100%
29689
29,689
2014
1.76
S.23
0 .14 Yrs
100%
35361
o
35,361
''"'
2015
2015
2016
""'
2016
2018
2017
2018
2018
2018
2018
2018
2018
2018
2018
2019
2019
201!1
201'
201'
201'
2011
2011
2012
2012
2012
2012
2012
2014
2014
2014
2014
2014
2015
2014
"'"
2015
2015
2015
2017
2017
2018
201&
2018
2018
2013
1.76
S.29
1.76
5.29
1.76~
0.52_..hl!.
0.52~
0.52 _.H!.
0.36________..lJ!_
0.49~
0.36
3.58
0.36
3.5.s
0.36
3.58
0.36
3.58
0.36~
0.36_±1!.
0.36~
0.36~
0.36_!J!_
0.36~
0.35 -----M!.
0.36~
0.36_1:&
0.36~
2.27~
2.27~
2.13~
2.13~
2.13 ---..!QQ.
2 .13~
2.U ____!&!Q.
2.13~
2.13~
2 • .13~
2.13-----Y!_
2 .13~
2.13~
2 .13~
2.13_..!J!.
2.13~
2.U ____!l!.
2.13--Y!,.
0,S9 --2.:2L
O.SS ____l...&
0.43~
0 .43--.....!:R
0.43~
0 .43 ----i:!!.
0.43
4.l2
Total
0.09 Yes
0,08 Yos
0 .11 Yos
0.13 Ye:;
0,11 Yin
0.11 Yo~
0.10 Yen.
0.11 Yci;
0.10 Yw.
0.12 YM
0.09 Yes
0.08 Yes
0,12 Ym.
0.09 y~
0.11 Y~
0 ,13 Yin
0 .10 Yos
0,14 y~
0 .06 Yes
0.10 Yes
0.12 YM
0.12 Yes
0.04 Yos
0.06 Yos
0.29 '{~
0.32 Yi;:s
0.34 y~
0.33 Yes
0.29 Yes
0.20 YH
0,2l Yes
0.21 Yos
0.22 Yes
0.19 y~
0.23Yt-$
0.l9YI!)
0.26 'fM
0.22Yes
0.21Yes
0.2SY.n
0.2SY.n
0.28Yt'S
0.24Yt:s
0.19Yes
0.17Ycs
0.16Y(!'_,,
O.OSYrs
U.5167
100%
24416
0
24,416
100%
20506
20,506
100%
29449
29,449
100%
25630
25,610
100%
33778
33,718
100%
33729
33,729
100%
28923
211.923
100%
21781
0
21,781
100%
2881.9
0
28,819
100%
3447S
0
34,475
100%
24494
o
24A94
100%
21829
21,8'29
100%
32571
32,571
100%
26418
26,418
100%
29646
2',646
100%
372S!I
37,258
100%
28419
28,41'J
100%
3"71
39,971
100%
16087
16,087
100%
2902S
0
29.028
100%
12640
n,&.co
1Cl0%
32629
32,629
100%
6S82
6,S82
0
100%
!XS4
9,554
100%
44860
0
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0
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52383
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44179
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43165
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43,165
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48470
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43865
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47449
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40841
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C8,660
100%
40237
0
40,237
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54653
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54,653
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46732
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100%
4439-5
0
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53036
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53,0~6
100%
42363
42,163
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48523
.:8,523
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56380
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45327
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" lnNAA•
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ave~c :innu.111 mllNIC!
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23
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REVISION TO ARIZONA’S SIP
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
APPENDIX 3:
EPA LETTER DATED AUGUST 18, 2021
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
Richard Sumner
Permitting Division Manager
Maricopa County Air Quality Department
3800 N. Central Avenue, Suite 1400
Phoenix, AZ 85012
Re: Comments on Proposed Permit Action for the Intel Corporation – Ocotillo Campus in Chandler, AZ
Dear Richard Sumner:
Thank you for the opportunity to review the Maricopa County Air Quality Department’s (MCAQD) July
21, 2021 proposed permit action for the Intel Corporation – Ocotillo Campus (“Intel”). In this action,
Intel is requesting authorization for a major modification to construct and operate two new
semiconductor Fab modules and supporting equipment (“Fab 52 and Fab 62”). The permit action also
relies on the MCAQD’s permits for three Waste Management, Inc. (WM) facilities to generate mobile
source emission reduction credits (MERCs) to be used as emissions offsets for the Intel project. This
letter and the enclosure provide the U.S. Environmental Protection Agency’s (EPA) comments on the
MCAQD’s proposed action and the WM permits. In developing our comments, we also reviewed the
requirements of Clean Air Act (CAA) section 173, the MCAQD’s State Implementation Plan (SIP)-
approved and non-SIP approved rules, and the EPA’s guidance document “Improving Air Quality with
Economic Incentive Programs” (January 2001).
Our comments focus primarily on ensuring the enforceability of the emissions offsets required for this
project under the CAA’s Nonattainment New Source Review (NNSR) program. This permit action
pilots an innovative approach of generating offsets by imposing requirements on a mobile source fleet
through the fleet owner’s CAA stationary source permit. Mobile sources are not typically subject to
CAA stationary source permitting requirements. In this case, the MERCs are being generated by WM’s
refuse truck fleets by switching diesel fueled vehicles to vehicles fueled with compressed natural gas
(CNG). This approach was used because the MCAQD does not currently have an EPA-approved
program in the MCAQD’s portion of the Arizona SIP for generating MERCs for the purpose of meeting
CAA stationary source permitting requirements.
The ability to generate MERCs through MCAQD-issued permits is based, in part, on our understanding
of the MCAQD’s authority to issue a stationary source permit that includes enforceable requirements for
mobiles sources that are under the control of the stationary source owner or operator. Thus, this option
may have limited application if the entity seeking to generate MERCs does not also have an enforceable
CAA stationary source permit. Our comments are as comprehensive as possible to ensure that the
permits issued to WM to generate the offsets upon which Intel is relying will meet the NNSR program’s
offset integrity requirements at the time construction is authorized.
Additionally, the MERCs being certified for this project appear to be good candidates for emissions
offsets because the vehicles that are the source of the credits are municipal refuse trucks that represent
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EPA Region 9 Comments – 8/18/2021
Intel – Ocotillo Campus, Major Modification
“captive fleets” (e.g., where all the vehicles in the fleet are identifiable, have GPS tracking equipment
installed, and return to base daily), their emissions are included in the MCAQD’s emissions inventory
used for ozone attainment planning, and they can be expected to operate at current or greater utilization
levels into the future. Also, the emission reductions associated with these MERCs have not been relied
upon in any demonstrations of attainment or reasonable further progress.
We are not aware of another instance of generating offsets from mobile sources by imposing
requirements on a mobile source fleet through the fleet owner’s CAA stationary source permit. Thus, the
EPA will continue to evaluate this approach to ensure all the NNSR program criteria are met. A SIP-
approved rule remains the EPA’s preferred approach for ensuring MERCs are generated in a manner
that meets the NNSR program’s criteria of being real, surplus, permanent, quantifiable, and federally
enforceable.
We appreciate your willingness to include us in the development of this permitting action and we look
forward to continuing to work with the MCAQD in meeting the CAA’s requirements, as well as our
shared goal of protecting human health and the environment.
If you have any questions regarding the EPA’s comments, please contact Lisa Beckham at (415) 972-
3811 or beckham.lisa@epa.gov.
Sincerely,
Laura Yannayon
Acting Manager, Permits Office
Air and Radiation Division
Enclosure
cc: Craig McCurry, Senior Environmental Engineer, Intel Corp
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EPA Region 9 Comments – 8/18/2021
Intel – Ocotillo Campus, Major Modification
Below are the EPA’s comments on the MCAQD’s July 21, 2021 proposed action to authorize the Fab 52
and Fab 62 project for the Intel Corporation – Ocotillo Campus under the New Source Review (NSR)
program through revisions to the facility’s title V permit. Our comments also relate to the permits issued
to three WM facilities, which Intel is relying on to generate emission reductions to meet the NNSR
program’s offset requirements.
1. Enforceability of Emissions Offsets Obligations in Intel’s Permit
a.
Intel’s draft permit does not contain enforceable conditions requiring Intel to use emissions
offsets certified by the MCAQD for the Fab 52 and Fab 62 project. Consistent with MCAQD
Rule 240 § 304.9.c, and in the same manner that MCAQD has made its Lowest Achievable
Emission Rate (LAER) determinations enforceable, the permit must include conditions
identifying the specific ton per year offset obligation applicable to this project (204.3 VOC
credits and 189.5 NOX credits) to ensure the reductions are an enforceable condition of the
permit to construct and operate.
b. Condition 2.c of Intel’s draft permit needs additional specificity to ensure its enforceability.
Consistent with the comment above, the condition should be expanded to include volatile organic
compounds (VOC) to ensure enforceability of the offset requirement for VOC. Additionally, it is
unclear what is meant by the nitrogen oxide (NOX) offset credits “shall be in effect” by the time
Intel commences operation of the project, as the emissions reductions that generate the offsets
credits must be federally enforceable prior to issuance of the authorization to construct
(consistent with CAA section 173(a)). Please clarify this condition to indicate that such emission
reductions must have occurred and/or been implemented prior to the project commencing
operation.
2. Permanency of Offsets Obtained from Waste Management
The offsets generated by WM are made federally enforceable through SIP-approved MCAQD Rule
220 § 302.2, which provides a means for permittees to accept voluntary, federally enforceable permit
conditions. However, the voluntary origin of the federally enforceable conditions affects whether
they meet the permanency requirements of the MCAQD’s NNSR program (MCAQD Rule 240 §
304.4). To ensure the permanency of these reductions, the MCAQD should submit the MERC permit
conditions in WM’s permits for approval into the MCAQD portion of the Arizona SIP. The EPA
will work with the MCAQD to help establish permanency of these offsets prior to the project
commencing operation.
3. Enforceability of Waste Management MERCs
Many of the conditions in the WM permits regarding the MERCs are too general to be enforceable
as a practical matter and insufficient for ensuring the offsets meet the offset integrity requirements in
MCAQD Rule 240 § 304.4 and are therefore valid. To ensure the offsets are valid, the WM permits
must be revised to identify the criteria upon which MCAQD is certifying the emission reductions,
including but not limited to: (1) the quantity in tons per year of credits generated by WM’s permit,
(2) the total number of CNG-powered vehicles that have been (or will be) used to generate the
offsets granted by the permit, (3) a list of the specific municipal refuse vehicles used to generate the
offsets (e.g., by serial/VIN), (4) the specific nonattainment area (e.g., Phoenix-Mesa ozone
nonattainment area) within which the CNG-powered vehicles must be operated, and (5) specific
monitoring and recordkeeping conditions for ensuring compliance with these requirements.
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EPA Region 9 Comments – 8/18/2021
Intel – Ocotillo Campus, Major Modification
For example, in response to this comment, an attachment could be added to the permit that is
referenced within the emission reduction credit (ERC) conditions that identifies items (1) through
(3). We would also recommend including a reporting requirement that WM submit an updated
version of the attachment annually.
4. Reporting Requirements for Waste Management
Because WM has ongoing obligations to ensure compliance with the information upon which the
ERC credits were certified, WM’s permits must include conditions to monitor ongoing compliance
through, at a minimum, an annual reporting requirement. The report should summarize how
monitoring/recordkeeping demonstrates that WM is continuing to ensure the emissions reductions
are being achieved. Other types of notifications should be considered, for example, what happens if a
CNG refuse truck is damaged or suffers significant maintenance issues that inhibits the truck from
generating the offset credits attributed to that truck.
5. Removal/Disposal of Replaced Refuse Trucks in Waste Management Permits
The current conditions in WM’s permits related to removal and disposal of replaced refuse trucks do
not ensure that all replaced trucks for which offset credits have been generated do not return to the
Phoenix-Mesa ozone nonattainment area. To meet the permanent and enforceable requirements for
valid offsets, WM’s permits must include additional requirements to monitor the operation of
replaced refuse trucks to ensure they do not return to the nonattainment area. This should include
monitoring and recordkeeping requirements to ensure that replaced trucks for which offset credits
were generated and that remain in operation (instead of being permanently disabled) are not being
used or will not be used in the Phoenix-Mesa ozone nonattainment area.
6. Monitoring of Equipment Use in Waste Management Permits
The ERC permit condition related to “monitoring of equipment use” appears to be intended to
require WM to monitor the operational parameters of the refuse trucks that were used in certifying
that the emission reductions for the project are real, surplus, and quantifiable. However, the
condition is not clear enough to make this requirement enforceable as a practical matter, as required
by MCAQD Rule 240 § 304.4. To ensure enforceability, the permit must specifically identify the
parameters that require ongoing monitoring and recordkeeping, and the method that will be used to
conduct the monitoring. We expect that the monthly monitoring and recordkeeping would include
factors such as vehicle miles traveled (VMT) for each refuse truck, VMT travelled while in service,
and the percent of VMT traveled within the nonattainment area.
7. Clarification of Several Waste Management ERC Permit Conditions
As described below, several of the conditions pertaining to the emission reductions in the WM
permits warrant additional specificity to ensure their practical enforceability:
a. Operation and Maintenance
The permit condition related to operation and maintenance is not fully enforceable because we
could not find a clear corresponding monitoring/recordkeeping provision related to this
requirement. This permit must include requirements to keep records onsite that demonstrate
compliance with this requirement.
b. Inspections
The permit condition related to inspections must further specify that the refuse trucks and
monitoring equipment can also be inspected.
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EPA Region 9 Comments – 8/18/2021
Intel – Ocotillo Campus, Major Modification
c.
Recordkeeping
In the recordkeeping section, it is unclear what the permit is referring to by “equipment
category.” This must be revised to provide more clarity. This section also allows WM to choose
which records they will maintain. As currently written, it appears WM could choose a different
monitoring parameter each month. It is unclear how such information would ensure
enforceability of the MERCs. For example, the ability to only monitor hours of operation would
not ensure the MERCs meet the offset integrity requirements. Please ensure the required
recordkeeping matches the monitoring data used to determine the quantity of offsets generated.
d. Terminology in ERC Conditions is Inconsistent
The permits’ ERC conditions seem to use the terms equipment, vehicle, and engine
interchangeably. Please review the final conditions to ensure consistent terminology. The
language of the ERC conditions needs to be specific enough to ensure that an inspector can
properly identify what they are looking for from the permit conditions. For example, identifying
the equipment as “refuse trucks” would significantly clarify the permit conditions. There is also
an instance where the term “generator” is used that we believe should be clarified to “Permittee.”
e.
References to Application
The permit conditions contain several references to the “application” used for generating these
emission reductions. These references appear to be intended to make specific elements of the
application enforceable, but they lack specificity, which likely makes them unenforceable. To the
extent any references to the “application” remain in the permit conditions after consideration of
our comments, such references must specify which portions of the application they refer to in
order to be able to make those provisions enforceable as a practical matter. One option might be
including portions of the application as an attachment to the permit.
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REVISION TO ARIZONA’S SIP
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
APPENDIX 4:
NOTICE OF PUBLIC HEARING
(Pending Affidavit of Publication)
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REVISION TO ARIZONA’S SIP
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
APPENDIX 5:
BOARD OF SUPERVISORS’ APPROVAL
(Pending Board of Supervisors’ Approval)
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REVISION TO ARIZONA’S SIP
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APPENDIX 6:
RELEVANT ARIZONA REVISED STATUTES
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Relevant Arizona Revised Statutes
49-112. County regulation; standards
A. When authorized by law, a county may adopt a rule, ordinance or regulation that is more
stringent than or in addition to a provision of this title or rule adopted by the director or any
board or commission authorized to adopt rules pursuant to this title if all of the following
requirements are met:
1.
The rule, ordinance or regulation is necessary to address a peculiar local condition.
2.
There is credible evidence that the rule, ordinance or regulation is either:
(a) Necessary to prevent a significant threat to public health or the environment that
results from a peculiar local condition and is technically and economically feasible.
(b) Required under a federal statute or regulation, or authorized pursuant to an
intergovernmental agreement with the federal government to enforce federal statutes
or regulations if the county rule, ordinance or regulation is equivalent to federal
statutes or regulations.
3.
Any fee or tax adopted under the rule, ordinance or regulation does not exceed the
reasonable costs of the county to issue and administer the permit or plan approval program.
B. When authorized by law, a county may adopt rules, ordinances or regulations in lieu of a state
program that are as stringent as a provision of this title or rule adopted by the director or any
board or commission authorized to adopt rules pursuant to this title if the county
demonstrates that the cost of obtaining permits or other approvals from the county will
approximately equal or be less than the fee or cost of obtaining similar permits or approvals
under this title or any rule adopted pursuant to this title. If the state has not adopted a fee or
tax for similar permits or approvals, the county may adopt a fee when authorized by law in
the rule, ordinance or regulation that does not exceed the reasonable costs of the county to
issue and administer that permit or plan approval program.
C. A county that adopts rules, ordinances or regulations pursuant to subsection B of this section
and that at any time cannot comply with subsection B of this section shall prepare and fil e a
notice of noncompliance with the director. The county shall post a copy of the notice of
noncompliance on the county's website with a date stamp of the date of posting. If the county
does not comply with subsection B of this section within one year after posting of the notice
on the county's website, the director shall provide written notice to and assert regulatory
jurisdiction over those persons and entities subject to the affected county rules, ordinances or
regulations.
D. Except as provided in chapter 3, article 3 of this title, before adopting or enforcing any rule,
ordinance or regulation pursuant to subsection A or B of this section, the county shall
comply with the following requirements:
1.
Prepare a notice of proposed rulemaking to include the proposed rule, ordinance or
regulation. This notice shall demonstrate evidence of compliance with subsection A or B of
this section. The notice shall include the name, address and phone number of a person who
can answer questions about the proposed rule, ordinance or regulation and accept any
written requests for the county to conduct an oral proceeding. The county shall post the
notice on the county's website with a date stamp of the date of posting. The county shall
publish the availability of the notice of the proposed rule, ordinance or regulation in a
newspaper of general circulation in the county. If there is no newspaper of general
circulation in the county, the county shall publish the notice in a newspaper of general
circulation in an adjoining county. If requested by the public, the county shall make available
a paper copy of the notice at a reasonable cost.
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2.
For at least thirty days after the posting of the notice of the proposed rule, ordinance or
regulation, afford persons the opportunity to submit in writing comments, statements,
arguments, data and views on the proposed rule, ordinance or regulation.
3.
Respond in writing to the comments submitted pursuant to paragraph 2 of this subsection
and post the county's response on the county's website. If requested by the public, the
county shall make paper copies of its comments available at a reasonable cost.
4.
Schedule a public hearing on the proposed rule, ordinance or regulation if a written request
for an oral proceeding is submitted to the county during the thirty-day comment period. The
county shall post the notice of oral proceeding on a proposed rule, ordinance or regulation
on the county's website. The county shall post the notice of oral proceeding at least twenty
days before the date of the oral proceeding. The county shall publish notice of any public
hearing required pursuant to this paragraph in any newspaper as prescribed by this title or
county ordinance. The county shall select a time and location for the public hearing that
affords a reasonable opportunity for the public to participate.
E. A county is not required to comply with subsection D, paragraphs 2, 3 and 4 of this section
before it adopts or enforces a rule, ordinance or regulation if the rule, ordinance or regulation
only incorporates by reference an existing state or federal rule or law that provides greater
regulatory flexibility for regulated parties and otherwise satisfies the requirements prescribed in
subsection B of this section.
F. Until June 30, 1995, a person may file with the clerk of the board of supervisors for that
county a petition challenging a county rule, ordinance or regulation adopted before July 15,
1994 for compliance with the criteria set forth in subsection A or B of this section. The
petition shall contain the grounds for challenging the specific county rule, ordinance or
regulation. Within one year after the petition is filed, the board of supervisors shall review the
challenged rule, ordinance or regulation and make a written demonstration of compliance with
the criteria set forth in subsection A or B of this section and challenged in the petition. Any
rules, ordinances or regulations that have been challenged and for which the board of
supervisors has not made the written demonstration within one year after the filing of the
petition required by this section become unenforceable as of that date. If a county has already
made a written demonstration under section 49-479, subsection C, for a rule, ordinance or
regulation, the person filing the petition shall state the specific grounds in the petition why that
demonstration does not meet the requirements of this section.
G. A rule, ordinance or regulation adopted pursuant to subsection A of this section may not
be invalidated subsequent to its adoption on the grounds that the economic feasibility
analysis is insufficient or inaccurate if a county makes a good faith effort to comply with
the economic feasibility requirement of subsection A, paragraph 2, subdivision (a), of this
section and has explained in the written statement, made public pursuant to subsection D
of this section, the methodology used to satisfy the economic feasibility requirement.
H. This section shall not apply to any rule, ordinance or regulation adopted by a county pursuant to:
1.
Title 36 for which the state has similar statutory or rule making authority in this title.
2.
Section 49-391.
3.
Chapter 3, article 8 of this title.
4.
Chapter 4, article 3 of this title and section 49-765.
5.
Nonsubstantive rules relating to the application process that have a de minimis economic
effect on regulated parties.
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49-474. County control boards
The board of supervisors of each county may authorize the board of health or health department
of their respective counties in cooperation with the department of environmental quality to:
1. Study the problem of air pollution in the county.
2. Study possible effects on adjoining counties.
3. Cooperate with chambers of commerce, industry, agriculture, public officials and all other
interested persons or organizations.
4. Hold public hearings if in their discretion such action is necessary.
5. The board of supervisors by resolution may establish an air pollution control district.
49-479. Rules; hearing
A. The board of supervisors shall adopt such rules as it determines are necessary and feasible to
control the release into the atmosphere of air contaminants originating within the territorial
limits of the county or multi-county air quality control region in order to control air pollution,
which rules, except as provided in subsection C shall contain standards at least equal to or
more restrictive than those adopted by the director. In fixing such standards, the board or
region shall give consideration but shall not be limited to:
1. The latest scientific knowledge useful in indicating the kind and extent of all identifiable
effects on health and welfare which may be expected from the presence of an air pollution
agent, or combination of agents in the ambient air, in varying quantities.
2. Atmosphere conditions and the types of air pollution agent or agents which, when present in
the atmosphere, may interact with another agent or agents to produce an adverse effect on
public health and welfare.
3. Securing, to the greatest degree practicable, the enjoyment of the natural attractions of the
state and the comfort and convenience of the inhabitants.
B. No rule may be enacted or amended except after the board of supervisors first holds a
public hearing after twenty days' notice of such hearing. The proposed rule, or any proposed
amendment of a rule, shall be made available to the public at the time of notice of such
hearing.
C. A county may adopt or amend a rule, emission standard, or standard of performance that is as
stringent or more stringent than a rule, emission standard or standard of performance for
similar sources adopted by the director only if the county complies with the applicable
provisions of section 49-112.
D. All rules enacted pursuant to this section shall be made available to the public at a
reasonable charge upon request.
49-480. Permits; fees
A. The board of supervisors may adopt a program for the review, issuance, revision,
administration and enforcement of permits and for public review of proposed permits for
sources that are subject to section 49-426, subsection A, that are not under the jurisdiction of
the state pursuant to section 49-402 and that are not otherwise exempt pursuant to section 49-
426, subsection B and subsection K of this section. This program shall include provisions for
administration, inspection and enforcement of general permits issued pursuant to section 49-
426, subsection H and subsection J of this section.
B. Procedures for the review, issuance, revision and administration of permits issued pursuant to
this section and required to be obtained pursuant to title V of the clean air act including sources
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that emit hazardous air pollutants shall be substantially identical to procedures for the review,
issuance, revision and administration of permits issued by the department under this chapter.
Such procedures shall comply with the requirements of sections 165, 173 and 408 and titles III
and V of the clean air act and implementing regulations for sources subject to titles III and V of
the clean air act. Procedures for the review, issuance, revision and administration of permits
issued pursuant to this section and not required to be obtained pursuant to title V of the clean
air act shall impose no greater procedural burden on the permit applicant than procedures for
the review, issuance, revision and administration of permits issued by the department under
sections 49-426 and 49-426.01 and other applicable provisions of this chapter.
C. Upon adoption of a permit program by the board of supervisors pursuant to this section, no
person may begin actual construction, operate or make a modification to any source subject
to the permit program without complying with the requirements of that program.
D. Permits issued pursuant to a program adopted under this section are subject to payment
of a reasonable fee to be determined as follows:
1.
For any source required to obtain a permit under title V of the clean air act, the board of
supervisors shall establish by rule a system of fees consistent with and equivalent to that
prescribed under section 502 of the clean air act. Such system shall prescribe procedures for
increasing the fee each year by the percentage, if any by which the consumer price index for
the most recent calendar year ending before the beginning of such year exceeds the
consumer price index for the calendar year 1989.
2.
For any facility subject to the permitting requirements of this chapter but not required to
obtain a permit under title V of the clean air act, the board of supervisors shall determine a
permit fee based on all reasonable direct and indirect costs required to administer the permit,
but not exceeding twenty-five thousand dollars.
The board of supervisors shall establish an annual inspection fee, not to exceed the average cost of
services.
E. Funds received for permits issued pursuant to this section shall be deposited in a special
public health fund and shall be used by the control officer to defray the costs of
implementing this article.
F. Permits issued pursuant to this section for a source required to obtain a permit under title V
of the clean air act shall, and for a source that is not required to obtain a title V permit may,
contain all of the following:
1.
Conditions reflecting all applicable requirements of this article and rules adopted pursuant to
this article.
2.
Enforceable emission limitations and standards.
3.
A schedule for compliance, if applicable.
4.
The requirement to submit at least every six months the results of any required monitoring.
5.
Any other conditions that are necessary to assure compliance with this article and the clean
air act, including the applicable implementation plan.
G. The control officer may refuse to issue any permit to any source subject to the requirements
of title V of the clean air act if the administrator objects to its issuance in a timely manner as
prescribed under title V of the act.
H. In the case of a permit with a term of three or more years issued pursuant to the requirements
of title V of the clean air act to a major source, the control officer shall require revisions to the
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permit to incorporate applicable standards and regulations adopted by the administrator
pursuant to the clean air act after the issuance of the permit. The control officer shall require
any revisions as expeditiously as practicable but not later than eighteen months after the
promulgation of such standards and regulations. No permit revision shall be required if the
effective date of the standards and regulations is after the expiration of the permit. Any permit
revision required pursuant to this subsection shall be treated as a permit renewal.
I. Except as provided in section 49-426, subsection B and subsection A of this section, any
person burning used oil, used oil fuel, hazardous waste or hazardous waste fuel in any machine,
incinerator or device shall first obtain a permit from the control officer. Any permit issued by
the control officer under this subsection shall contain, at a minimum, conditions governing:
1.
Limitations on the types, amounts and feed rates of used oil, used oil fuel, hazardous waste
or hazardous waste fuel which may be burned.
2.
The frequency and types of fuel testing to be conducted by the person.
3.
The frequency and type of emissions testing or monitoring to be conducted by the person.
4.
Requirements for record keeping and reporting.
5.
Numeric emission limitations expressed in pounds per hour and tons per year for air
contaminants to be emitted from the facility burning used oil, used oil fuel, hazardous waste
or hazardous waste fuel.
J. The board of supervisors may authorize by rule the control officer to issue a general permit
for a defined class of facilities if that class of facilities has not been issued a general permit by
the director for sources in that county pursuant to section 49-426, subsection H. The criteria
for issuance of a general permit are those applicable to the director pursuant to section 49-
426, subsection G.
K. The board of supervisors may identify by rule sources or classifications of sources for which a
permit is not required and pollutant-emitting activities and emissions units at permitted
sources that are not subject to inclusion in the permit. The criteria for exemptions granted
pursuant to this subsection are those applicable to exemptions granted by the director
pursuant to section 49 -426, subsection B.
L. In determining whether a permitting threshold established pursuant to this section applies to
an existing source, the control officer shall exclude particulate matter that is not subject to a
national ambient air quality standard under the clean air act.
M. The board of supervisors may adopt a rule or ordinance that establishes less burdensome
permit procedures and requirements for permits that are not required to be obtained pursuant
to title V of the clean air act. Until the effective date of a rule or ordinance adopted by a board
of supervisors pursuant to this section, the control officer, either on the control officer's own
initiative or on the request of a permit applicant, may waive requirements that are not
appropriate for non-title V sources.
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
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Return to Table of Contents
REVISION TO ARIZONA’S SIP
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
APPENDIX 7:
COMPILATION OF PUBLIC COMMENTS
REVISION TO ARIZONA’S STATE IMPLEMENTATION PLAN (SIP)
INCORPORATION OF WASTE MANAGEMENT PERMIT CONDITIONS
[Month - Year]
Page 73 of 73
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