Municipal Solid Waste Municipal Solid Waste Landfill NSPS/EG Landfill NSPS/EG

RequirementsRequirementsIllinois EPAIllinois EPA

Bureau of AirBureau of Air

Mike DavidsonMike Davidson217/782-2113217/782-2113

Important DatesImportant Dates

• March 12, March 12, 19961996

USEPA Promulgates the USEPA Promulgates the NSPS/EGNSPS/EG

• June 17, 1998June 17, 1998IEPA Promulgates 35 IAC 220IEPA Promulgates 35 IAC 220

Effect of the NSPS/EG -1Effect of the NSPS/EG -1• New Media (Air Emissions) to worry about.New Media (Air Emissions) to worry about.• Increased Scrutiny of Landfills from a Air Increased Scrutiny of Landfills from a Air

Emissions point of View.Emissions point of View.• Differing Terminology and Definitions from Differing Terminology and Definitions from

Land RegulationsLand Regulations• New Permit and Regulatory RequirementsNew Permit and Regulatory Requirements

– More Monitoring and TestingMore Monitoring and Testing– More RecordsMore Records– More ReportsMore Reports

Effect of the New Rules -2Effect of the New Rules -2

• Memorialization of Rule Requirements Memorialization of Rule Requirements in the Permitin the Permit

• Same Source/Collocation IssuesSame Source/Collocation Issues

Importance of NSPS/EG #1Importance of NSPS/EG #1

ApplicabilityApplicability: Primary trigger based : Primary trigger based upon the landfill meeting the Area upon the landfill meeting the Area Source Criteria in 40 CFR 63.1935(a)Source Criteria in 40 CFR 63.1935(a)(3)(3)

So Far To Date #1So Far To Date #1

Illinois EPA has Issued over Illinois EPA has Issued over 70 Title V Permits covering 70 Title V Permits covering either landfills and/or gas to either landfills and/or gas to energy facilities.energy facilities.

So Far To Date #2So Far To Date #2

No sources are classified as being No sources are classified as being either a major source of HAPs, co-either a major source of HAPs, co-located with a major source of located with a major source of HAPs or being a MSW landfill with HAPs or being a MSW landfill with a bio-reactor.a bio-reactor.

Importance of NSPS/EG #2Importance of NSPS/EG #2

Compliance:Compliance: Landfills compliance is Landfills compliance is based upon the NSPS, EG or based upon the NSPS, EG or Approved Alternative as per the Approved Alternative as per the NSPS/EGNSPS/EG

((40 CFR 63.1955(a) or (c))40 CFR 63.1955(a) or (c))

NSPS - ApplicabilityNSPS - Applicability

The NSPS applies to MSW landfills The NSPS applies to MSW landfills for which construction, for which construction, modification, or reconstruction modification, or reconstruction commences on or after May 30, commences on or after May 30, 19911991

EG – Applicability #1EG – Applicability #1

MSW landfills for which MSW landfills for which construction, modification, or construction, modification, or reconstruction commences before reconstruction commences before

May 30, 1991 May 30, 1991 is subjectis subject

EG – Applicability #2EG – Applicability #2

if the landfill has accepted waste if the landfill has accepted waste since November 8, 1987, or has since November 8, 1987, or has additional design capacity available additional design capacity available for future waste depositionfor future waste deposition

Title V RequirementTitle V Requirement June 10, 1996 for MSW landfills that June 10, 1996 for MSW landfills that

commenced construction, modification, or commenced construction, modification, or reconstruction on or after May 30, 1991 reconstruction on or after May 30, 1991 but before March 12, 1996; but before March 12, 1996;

Ninety days after the date of commenced Ninety days after the date of commenced construction, modification, or construction, modification, or reconstruction for MSW landfills that reconstruction for MSW landfills that commence construction, modification, or commence construction, modification, or reconstruction on or after March 12, 1996. reconstruction on or after March 12, 1996.

Control RequirementControl Requirement

• Design capacities greater than Design capacities greater than or equal to 2.5 million Mg and or equal to 2.5 million Mg and 2.5 million m2.5 million m33

• NMOC Emissions Greater than NMOC Emissions Greater than 50 Mg/yr 50 Mg/yr

NMOC EmissionsNMOC Emissions

• 40 CFR 60.754(a)(1)(i)40 CFR 60.754(a)(1)(i) nn

MMNMOCNMOC== 2 k L 2 k Loo M Mii ( e ( e-kt-ktii) (C) (C

NMOCNMOC) (3.6 x10) (3.6 x10-9-9))

i=1i=1

• 40 CFR 60.754(a)(1)(ii)40 CFR 60.754(a)(1)(ii)

MMNMOCNMOC=2 L=2 Loo R (e R (e-kc-kc - e - e-kt-kt) (C) (C

NMOCNMOC) (3.6 x10) (3.6 x10-9-9))

1.00

10.00

100.00

1000.00

Year

Mg

/Yr

NMOC Emission RateNMOC Emission Rate

CAA

AP-42

Tier 1; 40 CFR 60.754(a)(2)Tier 1; 40 CFR 60.754(a)(2)• No Testing RequiredNo Testing Required• Default Equation Values are UsedDefault Equation Values are Used• Calculation & Report Required Calculation & Report Required

Within 90 days of being affectedWithin 90 days of being affected

40 CFR 60.757(b)(1)(i)(B)40 CFR 60.757(b)(1)(i)(B)

Tier 2; 40 CFR 60.754(a)Tier 2; 40 CFR 60.754(a)(3)(3)

• CCNMOC NMOC Determination Required Determination Required

• Calculation & Report Required Calculation & Report Required Within 180 days after the first 50 Mg Within 180 days after the first 50 Mg exceedanceexceedance

40 CFR 60.757(c)(1)40 CFR 60.757(c)(1)

Tier 3; 40 CFR 60.754(a)(4)Tier 3; 40 CFR 60.754(a)(4)

• kk Determination Required Determination Required • Calculation uses the Tier 2 Calculation uses the Tier 2 CCNMOCNMOC

• Calculation & Report Required Within Calculation & Report Required Within 1 year after the first 50 Mg 1 year after the first 50 Mg exceedanceexceedance 40 CFR 60.757(c)(2)40 CFR 60.757(c)(2)

GCCS planGCCS plan

Landfill Gas Collection and Control Landfill Gas Collection and Control System Design Plan required within 1 System Design Plan required within 1 year of the first report which the year of the first report which the emission rate equals or exceeds 50 Mg emission rate equals or exceeds 50 Mg per year.per year.

40 CFR 60.752(b)(2)(i) and 60.757(c)40 CFR 60.752(b)(2)(i) and 60.757(c)

Collection System RequirementsCollection System Requirements Maximum gas flow rateMaximum gas flow rate Collect Gas from all areasCollect Gas from all areas

– 5 years or more if active; or 5 years or more if active; or –2 years or more if closed or at 2 years or more if closed or at

final grade. final grade. Sufficient Extract RateSufficient Extract Rate Minimize off-site MigrationMinimize off-site Migration

Control System : #1Control System : #1

• Open flare; or Open flare; or • A control system designed and A control system designed and

operated to reduce NMOC by 98% operated to reduce NMOC by 98% by weight; orby weight; or

Control System: #2(a)Control System: #2(a)

• A enclosed combustor which A enclosed combustor which reduces NMOC by 98 weight reduces NMOC by 98 weight percent or reduce the outlet NMOC percent or reduce the outlet NMOC concentrationconcentration

Control System: #2(b)Control System: #2(b)

to less than 20 parts per million by to less than 20 parts per million by volume, dry basis as hexane at 3 volume, dry basis as hexane at 3 percent oxygen.percent oxygen.

Control System: #3Control System: #3• Route the collected gas to a Route the collected gas to a

treatment system that processes the treatment system that processes the collected gas for subsequent sale or collected gas for subsequent sale or useuse

GCCS StartupGCCS StartupInstallation of Landfill Gas Collection Installation of Landfill Gas Collection and Control System Completed within and Control System Completed within 30 months after reporting NMOC 30 months after reporting NMOC emissions emissions 50 Mg/yr 50 Mg/yr

40 CFR 60.752(b)(2)(ii)40 CFR 60.752(b)(2)(ii)

Reporting Requirements #1Reporting Requirements #1

• Initial and annual design capacity Initial and annual design capacity reportreport

• NMOC emission reports (Annual or 5 NMOC emission reports (Annual or 5 year Reports)year Reports)

• Notification of increases in design Notification of increases in design capacity and NMOC emissionscapacity and NMOC emissions

Reporting Requirements #2Reporting Requirements #2• Submittal of design plans and Submittal of design plans and

construction permit applicationsconstruction permit applications• Compliance certificationsCompliance certifications• System Removal ReportsSystem Removal Reports• Annual Emission ReportAnnual Emission Report• Excavation in Asbestos AreasExcavation in Asbestos Areas

Recordkeeping #1Recordkeeping #1

• Control and Emission ExceedancesControl and Emission Exceedances• Location of AsbestosLocation of Asbestos• Waste Acceptance RateWaste Acceptance Rate• Asbestos Waste Shipment Records Asbestos Waste Shipment Records

Recordkeeping #2Recordkeeping #2

• Gas Collection and Control Gas Collection and Control Equipment Operating ParametersEquipment Operating Parameters

• New Well InstallationNew Well Installation• Monitoring ParametersMonitoring Parameters

Guidance and InfoGuidance and Info• USEPA’s WebsitesUSEPA’s Websites

NSPS -NSPS - http://www.http://www.epaepa..govgov//ttnttn//atwatw/landfill//landfill/landflpglandflpg.html.htmlMACT (AAAAMACT (AAAA) - ) - http://www.http://www.epaepa..govgov//ttnttn//atwatw/landfill//landfill/lndfillpglndfillpg.html.htmlUSEPA Applicability Determination USEPA Applicability Determination Index (ADI)Index (ADI) http://cfpub.epa.gov/adi/index.cfmhttp://cfpub.epa.gov/adi/index.cfm