Clean Air Act Requirements

Typical Tasks Performed:

• Tier 1 NMOC emission modeling
• Tier 2 testing
• Gas collection and control system design plans
• Gas collection and control system design, construction, operation, and maintenance
• Surface emission monitoring
• Wellfield monitoring
• Data analysis
• Compliance reports
• Startup, shutdown, and malfunction plans and reporting
• Expert witness

SCS’ general consulting philosophy regarding LFG and air quality issues at landfills is that the two are inseparable.  The primary air quality concern at landfills involves LFG emissions, and the main compliance tool in use at sites is the Gas Collection and Control System (GCCS).  Further, air quality regulations now dictate when the LFG system must be expanded to meet New Source Performance Standard (NSPS) requirements, and how it must be monitored to prove compliance.  As such, we always strive to achieve compliance with air quality requirements first; other LFG issues (e.g., lateral migration, impacts to groundwater, odor, etc.) tend to fall into place once a site has triggered the full range of NSPS criteria. 

Because of our philosophy about landfills, SCS is able to consider LFG planning and design and air quality compliance in all of our engineering projects.  But we have also learned to temper our engineering design and compliance programs with respect to the need to coexist with landfill operations.  One thing we have learned in working at landfills for over 30 years is that “operation is king.”

The promulgation of the NSPS and Emission Guidelines (EG) for MSW landfills in 1996 has had a significant effect on the landfill industry.  Because of this regulation, owners and operators of MSW landfills are required--some for the first time--to evaluate and possibly mitigate landfill air emissions.  Through our activities over the past 14 years (after the draft NSPS came out in 1991), SCS has become the nation’s leading authority on the NSPS rule and its implementation.

Under 40 CFR 63.1960, MSW landfill owners/operators are required to develop and implement a written Start-up, Shutdown, and Malfunction (SSM) plan according to the provisions in 40 CFR 63.6(e)(3).  A copy of the SSM plan must be maintained on site.  Failure to write, implement, or maintain a copy of the SSM plan deviates from the requirements of the landfill’s Maximum Achievable Control Technology (MACT), and would be considered a violation of the facility’s Title V permit, which incorporates the MACT standard as an applicable requirement.