1990 Clean Air Act Amendments – Title V Operating Permits Program

Landfill owners/operators must determine if their operation is classified as a major source of air pollutants under the 1990 Clean Air Act Amendments Title V Operating Permits Program. If a landfill operation is determined to be a major source, its owner/ operator will be required to apply for a Title V Air Permit from the state regulatory agency.

Title V is expected to be one of the most broadly applied regulations under the Clean Air Act. While application requirements and schedules for submittals will vary somewhat between states, the Title V Operating Permits Program brings new requirements to owners/operators of municipal solid waste landfill facilities. These air permitting requirements should not be confused with the requirements associated with the New Source Performance Standards and Emissions Guidelines for Municipal Solid Waste Landfills (NSPS).

To determine if their landfill operation is a major source, owners/operators must calculate facility emissions and complete an emissions inventory. The emissions calculations can be based upon actual sampling data or mass balances, or on the use of emission factors approved by the U.S. Environmental Protection Agency. If the calculations reveal that the operation is a major source of air pollutants, the owner/operator must submit a Title V permit application.

A major source is defined in three sections of the Clean Air Act:

  • Section 112: A stationary source that emits or has the potential to emit 10 tons per year (tpy) or more of any hazardous air pollutant (HAP) or 25 tpy or more of any combination of HAPs, including fugitive emissions. HAPs typically generated at municipal landfills include benzene, toluene, ethyl benzene, xylenes, and vinyl chloride.
  • Section 302: A stationary source that emits or has the potential to emit 100 tpy of a regulated pollutant. Regulated pollutants at municipal landfills include carbon monoxide, nitrogen oxide, sulfur dioxide, volatile organic compounds, and particulate matter. Sources of these emissions include the landfill itself, leachate management systems, landfill gas flares, engine generators, and fuel storage facilities.Once the NSPS are promulgated, fugitive emissions from the landfill facility (e.g., from excavation, screening, crushing, construction activities, or dust from haul roads) will be included in the emissions inventory.
  • Title I, Part D: For landfills located in non-attainment areas, the 100 tpy threshold for regulated pollutants is reduced to 50 tpy, 25 tpy, and 10 tpy, in accordance with the non-attainment classification (i.e., serious, severe, and extreme).

States’ requirements to comply with the Title V Operating Permits Program may vary. For further information on air permitting requirements, schedules for submittals, or assistance in preparing emissions inventories, please contact:

Eric Peterson, PE, Project Director
Greg Vogt, Vice President
SCS Engineers
11260 Roger Bacon Drive
Reston, VA 22090
(703) 471-6150

Technical Bulletins are prepared by SCS Engineers to alert clients to potential issues which can affect their businesses.

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