The EPA and, in some cases, states are rolling out new emissions guidelines at least as stringent. The EPA estimates that the plans could cover about 1,600 landfills. These landfills are in 41 states, tribal entities, and the U.S. territories of Puerto Rico and the Virgin Islands.
MSW landfills without Gas Collection and Control Systems (GCCS) that reach a specific threshold will need to add these systems and have 30 months to install or update control systems to meet new standards. As you’ve noticed by now, we’ve greatly oversimplified what is happening.
The new regulations and timetables are difficult to understand and untangle. SCS Engineers, in concert with SCS Field Services, have prepared resources to help during the transition period and afterward when landfills are likely to need more monitoring and measurement, thus creating millions of more bits of data to store, analyze, and report.
We hope you find these resources useful. We will be publishing more soon.
These resources may help you with future monitoring and maintenance:
Thank you to the many folks attending SCS’s live webinar on July 15th about managing the NESHAP, NSPS/EG transition period. As promised, we’ve created a library of resources for you to use and share with your colleagues.
These resources may help you with future monitoring and maintenance:
We’re here to help. Please find an expert or contact us at .
The EPA’s published clarifications, technical revisions, and new rule versions for the National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for MSW landfills may feel like alphabet soup right now.
SCS Engineers’ upcoming webinar and open Q/A forum on July 15, 2021, at 1:30 Eastern Time is free and could help keep you informed and on track for compliance by September 27, 2021.
Our panelists will advise on the essential key information, deadlines, and changes to field operations to address during the transition from the old to the new NESHAP and NSPS rules.
• Surface emissions monitoring;
• Wellhead monitoring and corrective action requirements;
• Delegation of authority to the state, local, or tribal agencies for emission standards;
• Applicability of the General Provisions under 40 CFR 63, Subpart A to affected landfills;
• Monitoring data for control devices during startup, shutdown, and malfunctions (SSM);
• Gas collection and control system installation;
• Compliance timing and reporting;
• Open question and answer throughout the webinar.
The EPA’s published clarifications, technical revisions, and new rule versions for the National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for MSW landfills may feel like alphabet soup right now.
SCS Engineers’ upcoming webinar and open Q/A forum on July 15, 2021, at 1:30 Eastern is free and could help keep you informed and on track for compliance by September 27, 2021.
Our panelists will advise on the essential key information, deadlines, and changes to field operations to address during the transition from the old to the new NESHAP and NSPS rules.
• Surface emissions monitoring;
• Wellhead monitoring and corrective action requirements;
• Delegation of authority to the state, local, or tribal agencies for emission standards;
• Applicability of the General Provisions under 40 CFR 63, Subpart A to affected landfills;
• Monitoring data for control devices during startup, shutdown, and malfunctions (SSM);
• Gas collection and control system installation;
• Compliance timing and reporting;
• Open question and answer throughout the webinar.
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website.
Our most recent Bulletin summarizes the 2020 Virginia State Plan for New Landfill EG approved by the USEPA on June 23, 2020.
The Environmental Protection Agency (EPA) approved a Clean Air Act (CAA) section 111(d) plan submitted by the Virginia Department of Environmental Quality (VADEQ). This plan was submitted to fulfill the requirements of the CAA and in response to EPA’s promulgation of Emissions Guidelines and Compliance Times for municipal solid waste (MSW) landfills.
The Virginia plan establishes emission limits for existing MSW landfills and provides for the implementation and enforcement of those limits. Highlights of the plan are explained in a newly published SCS Technical Bulletin.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed.
The updates to air regulations intend to remove redundant requirements and reduce compliance burdens where environmentally appropriate.
The U.S. Environmental Protection Agency (EPA) proposed updates to the oil and natural gas industry national standards. The proposal intends to remove regulatory duplication while maintaining health and environmental regulations on oil and gas sources that the agency considers appropriate. The proposal is the result of EPA’s review of the 2016 New Source Performance Standards (NSPS) for the oil and natural gas (O&G) industry conducted in response to Executive Order 13783 – Promoting Energy Independence and Economic Growth. The goal was to review existing regulations that could potentially “burden the development or use of domestically produced energy resources,” including oil and natural gas.
The resulting regulatory impact analysis from EPA estimates that the proposed amendments could save the O&G industry $17-$19 million a year, for a total of $97-$123 million from 2019 through 2025.
“EPA’s proposal delivers on President Trump’s executive order and removes unnecessary and duplicative regulatory burdens from the oil and gas industry,” said EPA Administrator Andrew Wheeler. “The Trump Administration recognizes that methane is valuable, and the industry has an incentive to minimize leaks and maximize its use. Since 1990, natural gas production in the United States has almost doubled while methane emissions across the natural gas industry have fallen by nearly 15%. Our regulations should not stifle this innovation and progress.”
In its primary proposal, the agency is proposing to remove sources in the transmission and storage segment of the O&G industry from regulation. These sources include transmission compressor stations, pneumatic controllers, and underground storage vessels. The agency is proposing that the addition of these sources to the 2016 rule was not appropriate, noting that the agency did not make a separate finding to determine that the emissions from the transmission and storage segment of the industry cause or significantly contribute to air pollution that may endanger public health or welfare.
The primary proposal also would rescind emissions limits for methane, from the production and processing segments of the industry; keeping emissions limits for ozone-forming volatile organic compounds (VOCs). These sources include well completions, pneumatic pumps, pneumatic controllers, gathering and boosting compressors, natural gas processing plants and storage tanks. The controls to reduce VOCs emissions also reduce methane at the same time, so separate methane limitations for that segment of the industry are redundant.
In an alternative proposal, EPA would rescind the methane emissions limitations without removing from regulation any sources from the transmission and storage segment of the industry.
The agency also is seeking comment on alternative interpretations of EPA’s legal authority to regulate pollutants under section 111(b)(1)(A) of the Clean Air Act.
This proposal is in addition to a September 2018 technical action that proposed targeted improvements to help streamline implementation, reduce duplication of EPA and state requirements, and significantly decrease unnecessary burdens on domestic energy producers. EPA is currently reviewing comments received on that technical package and expects to issue a final rule in the upcoming months.
EPA will take comment on the proposal for 60 days after its publication in the Federal Register, and will hold a public hearing. EPA will announce details of the hearing shortly.
More information, including a pre-publication version of the Federal Register notice and a fact sheet, is available at https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry
Link to the proposal: https://www.epa.gov/sites/production/files/2019-08/documents/frn_oil_and_gas_review_2060-at90_nprm_20190828revised_d.pdf
Link to fact sheet:
Air Monitoring at SCS Engineers / O&G Services
This article discusses global air quality and how the collaboration between policy-makers and the scientific community can have a continued positive impact on air quality in the U.S. This collaboration has been the primary cause for the improvements observed in air quality over the past few decades.
U.S. Environmental Protection Agency (EPA) programs, such as the New Source Performance Standards (NSPS), New Source Review, and Maximum Achievable Control Technology standards, have all had a significant impact on improving air quality by lowering the ambient concentrations of NOX, VOC, CO, SOX, and PM.
Some areas, such as southern California, have committed to working toward electrifying the transportation network, implementing more stringent standards on diesel fuel sulfur content, and encouraging heavier utilization of public transportation.
Author: SCS Engineers’ Ryan Christman, M.S., is an air quality engineer and environmental management information systems specialist with experience in the oil and gas industry and the solid waste industry. He is just one of SCS’s outstanding Young Professionals.
SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. Our most recent SCS Bulletin summarizes the new rules which took effect on October 28, 2016, with compliance obligations under the NSPS Subpart XXX rule beginning November 28, 2016. Originally, states and local air jurisdictions were to submit their proposed EG rules by May 30, 2017; however, there have been some delays in this process, which we condense and detail in this Bulletin. SCS will continually update coverage of this Rule on our website.
Read and share the full article by David Greene, PE, here.
EPA recently established expansive new air rules affecting MSW Landfills. Implementation of the new rules places new responsibilities on both the regulated community and regulators alike. However, some of these responsibilities are unclear and have created unresolved issues that should be addressed in close consultation now with your state/local regulatory authority.
For example, if a landfill is “new,” the facility is now subject to NSPS Subpart XXX, which is fully effective. A design capacity and NMOC emissions rate report should already have been submitted.
If NMOC emissions from a facility exceed 34 Mg/yr, then the landfill will need to submit a GCCS design plan within 12 months of the date of exceedance and install and operate within 30 months (no later than May 2019 for those triggering with the promulgation of the rule). If a landfill is an “existing emissions source,” it will be subject to the new EG rule (Subpart Cf).
Landfill owners should maintain close contact with their state/local regulatory authority regarding the status of the regulator’s state implementation plan, due by November 2017. That state implementation plan will prescribe the required compliance dates for an existing landfill, likely to be no later than the 2018/2020 time period. In either case, owners should become familiar with the rule and stayed tuned as compliance guidance evolves to address the unresolved issues.
Contact SCS Engineers to discuss the regulatory status in your state at , or call your local representative.
Getting a firm handle on a solid waste operation and expenses is a challenge for any solid waste agency manager or landfill operator. It is particularly imperative in this era of “lean and mean” budgets and looming regulatory policy. Doing more with less is the watchword for most operations across the country still reeling from the financial impacts of the Great Recession.
SCS Engineers has created a package of articles to help you identify if your landfill, landfill gas, or solid waste operation is ready for 2017. We hope this useful guidance will help you plan for the upcoming year. SCS professionals are always available to answer questions and provide advice. Find the office or SCS professional nearest to you by clicking on one the links here: Offices and Professionals.
Download, print or share this package by using the download button under the articles or by using the navigation at left. The package includes the following information written by SCS National Experts:
