MDE Regulatory Alert: Maryland Landfill Air Regulation
On December 30, 2022, the Maryland Department of the Environment (MDE) published a proposed regulation addressing the control of landfill gas (LFG) methane emissions from municipal solid waste (MSW) landfills in the state. Methane is a potent greenhouse gas (GHG) with a global warming potential of more than 25 times greater than carbon dioxide. The proposed regulation is modeled after similar rules in California and Oregon, incorporates provisions from the EPA’s federal landfill air regulations under NSPS & EG 40 CFR 60 Subparts Cf and XXX and NESHAP CFR 63 Subpart AAAA, and would become among the most stringent in the US.
The new regulation will be submitted to the EPA for approval as part of Maryland’s state plan for MSW landfills (state plan). The state plan will be equivalent to or more stringent than the EPA’s NSPS & EG 40 CFR 60 Subparts Cf and XXX and NESHAP CFR 63 Subpart AAAA, and will apply to smaller and mid-sized landfills not currently subject to the EPA’s federal rules.
MDE estimates that 32 active and closed MSW landfills in the state will be subject to the proposed regulation.
Some key provisions of the rule include:
This rulemaking has been several years in development and is consistent with Maryland’s GHG Reduction Act of 2009 and the recent Climate Solutions Now Act of 2022 that requires Maryland to become “net zero” for GHG emissions by 2045, with an interim goal of achieving 60% GHG reductions by 2031 (over 2006 levels). MDE estimates that once implemented, this rule will achieve a 25-50% reduction in GHG emissions from affected landfills. MDE estimates the capital costs associated with rule compliance would range from $1 to $3 million, annual operating and maintenance costs range from $150k to $400k, and additional costs for monitoring (~ $60k annually), recordkeeping, and reporting.
MDE has scheduled a virtual public hearing on the proposed action at 10:00 am on February 1, 2023. Comments can be submitted by 5:00 pm (Eastern Time) on February 1, 2023, to Mr. Randy Mosier of MDE at .
For additional information on MSW regulations and GHG emission reductions, please visit scsengineers.com or one of SCS’s nationwide offices.
Compounded by rising labor and regulatory costs, landfill operations challenges for owners and operators are liquids and greenhouse gases. Gas collection and control systems, leachate management strategies, and treatment technologies all help create efficiencies. But so does new technology.
In our two-part educational series, we use case studies to demonstrate combinations of integrated SCADA, IIoT, drones, satellites, and Geographical information systems (GIS) technologies. Using clear, straightforward language, our panelists explain which technology is best for what and when integrating these technologies better serves your landfill’s and composting operation’s challenges and budget.
Recorded in front of a live audience who send questions to our panelists specific to their operational needs we cover monitoring, liquids, and labor challenges – with an aim to introduce new technologies that solve some of your most expensive challenges. SCS’s forums are educational, non-commercial webinars with a Q&A forum throughout; they are free and open to all who want to learn more about landfill and composting technology. We recommend these discussions for landfill and organics management facility owners/operators, technicians, environmental engineers, municipalities, and environmental agency staff.
View Part I focused on drones, satellites, and GIS technologies which are valuable for landfill permitting, design, and monitoring liquids and gas well conditions.
View Part II focused on SCADA and remote monitoring & control systems – when and why using real-time data can create efficiencies and reduce risk at your landfill and are useful for compost operations, and anaerobic digestors.
If you would like to join our mailing list for these monthly forums, please contact us at – SCS never shares or sells your contact information.
The U.S. Environmental Protection Agency (EPA) has issued a proposed rulemaking (Federal Register, Vol. 87, No. 198, Friday, October 14, 2022) that would address a 2008 Fugitive Emissions Rule that was subsequently granted reconsideration based upon a petition from the National Resources Defense Council (NRDC). The key issue is how fugitive emissions are considered under Section 111 of the Clean Air Act (CAA), as related to the definition of modification.
Modification means any physical change in, or change in the method of operation of, a stationary source which increases the amount of any air pollutant emitted by such source or which results in the emission of any air pollutant not previously emitted. 42 U.S. Code § 7411(a)(4).
In 2008, the Bush EPA published its Fugitive Emissions Rule that sought to “reconsider” the inclusion of fugitive emissions under this language. Fugitive emissions are defined as:
Those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally-equivalent opening.
NRDC’s petition for reconsideration argued that the Bush EPA weakened the standard for determining major modifications by excluding fugitive emissions from major Prevention of Significant Deterioration (PSD) and non-attainment New Source Review (NSR) applicability.
The proposed rulemaking would result in a formal reversion to the pre-2008 language. EPA’s Director for its Office of Air Quality Planning & Standards (OAQPS) has indicated that the rule “would require fugitives to be counted in all new and modified major source determinations,” effectively ending the Bush-era limitations on counting of fugitive emissions.
The potential impact of EPA’s planned fugitive emissions rule may prove significant and is expected to affect a wide range of diverse industry sectors being impacted, such as power generation, oil & gas extraction, mining, paper mills, petroleum refining, chemical manufacturing, coatings operations, and solid waste facilities. In particular, both landfills and compost facilities can have significant fugitive emissions.
Based on our current understanding, the proposed rule will effectively eliminate the ability to exempt fugitive emissions under the current exemption in 40 Code of Federal Regulations (CFR) 52.21(i)(vii). This would mean that if a source is an existing major PSD or non-attainment NSR source for ANY pollutant, and modifies, then both non-fugitive AND fugitive emissions for ALL pollutants must be counted to see if the project is a major modification under PSD/NSR. Triggering a major modification would also mean that fugitive emissions are included in the various compliance elements of PSD or NSR (e.g., best available control technology [BACT], lowest achievable emission rate [LAER], modeling, offsets. etc.).
To add more context for landfills, as an example, if an existing landfill, which is already deemed major due to carbon monoxide (CO) or sulfur dioxide (SOx) emissions from flares (Potential to Emit [PTE] >250 tons per year [tpy]), conducts an expansion that will result in 15 tpy of new particulate matter less than 10 microns(PM10) [and/or 10 tpy of PM2.5] fugitive emissions from windblown dust, this would be a major modification under PSD, requiring BACT and modeling for fugitive PM. This could also include BACT and other requirements for fugitive methane as a regulated greenhouse gas (GHG) or volatile organic compounds (VOCs)/non-methane organic compounds (NMOCs) from the additional fugitive landfill gas (LFG) emitted from the expanded landfill. Compost facilities can also have significant VOC emissions, which could put them at risk from this rule change.
Public comment on the rulemaking ends on February 14, 2023, which is an extension of the previous deadline. The solid waste industry will provide comments through the Solid Waste Association of North America (SWANA) and the National Waste and Recycling Association (NW&RA). This will be the last chance to have any effect on the rulemaking. Otherwise, landfills and possibly compost facilities could face more stringent requirements under the PSD and NSR programs when it comes to fugitive emissions.
Landfill and compost facility owners and operators may direct their questions pertaining to specific facilities to their Project Managers or .
Many landfills are still using hand-held monitoring of methane “hot spots” for compliance purposes while relying on models to estimate LFG emissions. Although technological developments in optical remote sensing and other methods offer significant improvements to measuring actual surface emissions from landfills, no single technology or method has risen to the top of the scientific hierarchy, gained universal acceptance, and achieved regulatory approval. Clearly, the technological advances provide more comprehensive methods for measuring methane concentration, identifying methane hot spots and leaks, and providing better coverage of the entire landfill surface. However, some technology falls short in their ability to provide accurate, consistent, and repeatable methane flux or emissions measurements.
As monitoring technology evolves, so have the various ways SCS takes measurements, from source level, drones, and high-altitude aircraft, to satellites. This paper presented at A&WMA by Patrick Sullivan and Raymond Huff summarises and provides details on the following methods:
• First order decay (FOD) modeling for landfills without active LFG collection systems.
• Non-FOD modeling for landfills without active LFG collection systems.
• FOD modeling with measured LFG collection.
• Non-FOD models with various site-specific data input.
• Measured LFG collection with estimated collection efficiency.
• Surface emission monitoring for compliance purposes.
• Ground-based or low-altitude imaging for concentration or hot spot measurement.
• Satellite and aerial imaging for concentration or hot spot measurement.
• Flux chamber testing.
• Ground-level plume measurement.
• Micrometeorology.
• Stationary path measurement.
• Reverse air dispersion modeling.
• Tracer studies.
• Low or high-altitude imaging.
• Hybrid methods.
While performing methane reduction operations and monitoring at the Anchorage Regional Landfill in Alaska, members of the SCS RMC drone team met some pretty amazing people, including Shane Christiansen who works for the Municipality of Anchorage. The RMC team got to know Shane and learned how he and his business partner, Tim Harrington, are helping disabled children.
Shane and Tim run an organization called Children Leaving Tracks (CLT) that has the mission of providing mobile technologies to young people with limited mobility, allowing them to participate more fully in everyday activities with their peers. They believe that providing improved mobility can expand the physical and mental well-being of these kids and offer them greater freedom and quality of life.
Moved by Shane and Tim’s passion and dedication, SCS made a donation, which will provide “Electric All-Terrain Trikes” to three children! “Everyone deserves to have these experiences in life, but unfortunately this kind of technology is not always covered by insurance companies,” says Shane. “This means that some people go their entire life without getting to enjoy all that it has to offer. They don’t have the freedom to [move about] as they please.”
Although still in the early stages, Children Leaving Tracks seeks financial and in-kind donations from sponsors and networking partners. They are working toward creating a corporate/private collaboration that has the single mission of helping disabled children become more mobile for their health and personal growth.
CLT uses funding to run the organization to supply and finance Track Chairs and Electric Trikes. Donations cover the costs of purchasing and shipping these chairs to the kids who need them. Shane and Tim are registering Children Leaving Tracks as a 501c3 non-profit company; they are also starting a parent company aimed to be the primary funding arm that will supply a percentage of revenues from more recreational products it plans to develop.
The ultimate goal is to change the lives of hundreds of children by opening up their world through greater mobility and freedom. The organization helps youngsters gain confidence, better mental and physical health, and create greater opportunities to expand their individual talents. Kudos to Children Leaving Tracks!
Learn more about how this inspirational organization uses new technology to make life better; or to help, please contact Shane Christiansen at 1-907-529-5153.
If you would like to know more about using technology to improve the environment, ask SCS click here.
SCS Engineers is providing landfill gas (LFG) systems operations, monitoring, design, and management for the Yolo County Central Landfill (YCCL). SCS Field Services is SCS’s specialized landfill practice, providing operations, maintenance, and monitoring (Landfill OM&M) for Yolo County and over 600 landfills across the nation.
SCS Field Services identifies practical strategies to optimize the performance of landfill gas (LFG) systems and equipment while working on site. Optimized systems capture more gas.
Project Manager Mike Calmes leads the comprehensive team at YCCL, which has five closed waste management units, five active waste management units, and one under construction. Closed landfills continue generating gas, so active or closed, they all require oversight by these landfill specialists.
“The County understands the importance of preventative strategies using captured landfill data to create sustainable environmental controls. These keep landfills running as efficiently as possible and safely within regulatory compliance,” said Anton Z. Svorinich Jr., SCS Engineers Vice President, Regional OM&M Manager.
To learn more about landfill operations and engineering, visit SCS Engineers.
Landfill efficiency: every landfill owner or operator knows that landfills are distinctly unique. Consequently, landfill gas collection and control systems (GCCS) and leachate management systems with highly engineered components are configured precisely to tailor to each landfill’s needs. North American landfills have always tried to be good neighbors, but now are making greater strides toward reducing emissions and protecting groundwater with master planning and technology. These plans keep the effectiveness of these systems running as efficiently as possible and help prevent expensive and extensive repairs.
Today’s blog takes us out in the field examining how to plan for these flexible high-dollar infrastructure systems. These plans are taking landfill operations into the future and are adaptable to changing regulations around emissions and the evolving waste streams that affect gas production.
We’ll also provide resources to similar articles about leachate systems, remote monitoring systems, drones, and carbon sequestration that are helping to keep your carbon footprint even lower and support landfill efficiency.
In the April issue of WasteAdvantage Magazine, Professional Engineers Vidhya Viswanathan and Maura Dougherty discuss how operators with 5-year and master plans in place get a payoff with a system that serves them well and costs less. They can prepare early for capturing their gas, use the plan to install gas collection infrastructure on a timely basis, and help guide them through post-closure among the daily benefits. Read Master Plan to Lower Your Landfill GCCS Infrastructure Investments here.
Planning/Managing Leachate/PFAS
Remote Monitoring and Control and Drones
The City Council of the City of Lincoln, Nebraska, recently approved a four-year service agreement with SCS Engineers for comprehensive environmental solutions and technology supporting the Solid Waste Management Division and Lincoln Water System.
The contract provides professional engineering and technical support for the City’s two Solid Waste Management Facilities, located on Bluff Road and North 48th Street in Lincoln. Modern landfills such as these contain complex systems to protect the health of nearby communities and the environment. Lincoln’s Solid Waste Management Division uses SCS professionals’ expertise and proprietary software for air quality and gas collection and control systems (GCCS), operations, monitoring, and maintenance. These environmental services keep the landfills fully compliant with regulatory requirements while aligning with the City’s system performance goals and anticipated operational and maintenance activities.
The City is using SCSeTools® software designed for landfills to support managing the monitoring data to gauge operational health continually. The firm’s comprehensive environmental services include sampling and monitoring groundwater, stormwater at both facilities, and leachate analysis at the Bluff Road Landfill.
SCS assists with scheduled testing and reporting to federal, state, and local agencies, including the Environmental Protection Agency, Nebraska’s Department of Environment and Energy, and the Lincoln-Lancaster County Health Department. Primarily these public reports cover monitoring summaries, statistical analyses of analytical results, and review of emission sources, factors, and calculations associated with the GCCS. They also include greenhouse gas reports, estimates, Title V permit requirements and documentation, NPDES General Permit support, and Stormwater Pollution Prevention Plans.
Michael Miller, an SCS vice president and one of the firm’s environmental due diligence experts, said,” We’re privileged that the City of Lincoln entrusts us to partner with its professionals to maintain the landfills’ safe and efficient operations. The Solid Waste Management Division and Lincoln Water System support the citizens with essential services and the environment; we’re honored to assist.”
SCS Engineers shows you in this short video featuring SCS Remote Monitoring & Control technology built for landfill owners and operators, solar farms, and for use on pipelines by SCS Engineers, landfill and environmental practitioners.
The Reno County Board of Commissioners approved contracting with SCS Engineers to support the County’s Solid Waste Department through 2024. SCS will provide environmental engineering, consulting, and field services for the Reno County Municipal Solid Waste Facilities for the next three years. The contract approval directly resulted from the firm’s experience, expertise, and long-standing relationship with Reno County.
SCS has a history of providing compliance, planning, and engineering services to Reno County. The firm helps the County continually comply with the Kansas Department of Health and Environment (KDHE) and other agency regulations. Compliance activities throughout the year include groundwater and leachate sampling, laboratory analyses, permit renewals, air permitting, and associated report preparation in accordance with Kansas Administrative Regulations.
Landfills contain complex systems to protect the health of nearby communities and the environment. The County uses SCS professionals’ expertise and proprietary software for air quality and gas collection and control systems (GCCS) operations, monitoring, and maintenance (OMM). Reno County relies on SCS to maintain these systems and keep them in compliance to focus on their other operations.
These preventative services keep the landfills fully compliant with state and federal regulatory requirements while aligned with the County’s system performance goals and anticipated operational and maintenance activities.
In 2021 the U.S. Environmental Protection Agency (EPA) changed legislation regulating landfills, specifically the New Source Performance Standards (NSPS) and other air quality regulations. These changes significantly increased the monitoring, record-keeping, data management, and reporting tasks for many landfills across the nation, including the Reno County Facility. SCS has helped Reno County navigate these changes and will continue to facilitate changes as the County looks to expand its landfill in the future. Combined with the supply chain and labor shortages, the Solid Waste Department is securing its essential services from disruptions.
Project Director Steve Linehan said, “SCS is privileged that Reno County entrusts us to partner with them to maintain the landfills’ safe and efficient operations. The Solid Waste Department supports the citizens and the environment; we’re honored to help.”
