Learn about SCS Engineers Air Emissions Services
EPA is hosting a free workshop in January on landfill monitoring and emissions. The workshops are scheduled twice, over half-day sessions. These sessions will include presentations highlighting the latest technological developments for monitoring and measuring landfill gas emissions.
Dates and Times: Register once for both sessions.
If you have any questions, please contact Shannon Banner at or John Evans at .
SCS Engineers’ newest environmental technology application is for use at solid waste facilities and landfills. These sites require specific monitoring and analyses of groundwater and liquids, landfill gas – LFG, and surface emissions critical to facility infrastructure and the environment.
“We work side-by-side with our clients at hundreds of facilities nationwide. SCS MobileTools® supports operating decisions, whether our client is managing one site or hundreds,” states Pete Carrico, senior vice president and assistant director of SCS Field Services.” The App’s interface gives clients quick access to information that drives critical operating decisions and provides data for corporate directives and landfill gas OM&M programs for regional or national operations.
SCS MobileTools® is the iOS and Android mobile interface for the SCSeTools® platform. Access to data to make informed decisions is especially valuable when technicians are in the field, or operators are working remotely. Landfill and solid waste facility owners, operators, and technicians use the new application to observe system and environmental activity securely and in real-time on a mobile phone or device.
Featuring state-of-the-art technology, SCS MobileTools® provides users the ability to interact with a site or facility data, including site-specific monitoring and exceedance metrics for landfill gas, liquid levels, and surface emissions. Responsive, touch-enabled flow data charting is accessible, illustrating flow targets, reading dates, flow rates, and historical flow data analysis.
When compared year-over-year, generation and disposal trends produce information critical to assessing optimal options and solutions that represent significant savings for landfill gas Operations, Maintenance & Monitoring – OM&M programs. For this reason, the savings compound for regional or national operators.
For instance, monitoring and analyzing landfill gas generation and collection data against modeled estimates are valuable information. SCS MobileTools® handles the input, analysis, review, and export of landfill gas flow and related information, specifically flow rates, impacts on gas collection (e.g., extraction well liquid levels), and analytical data for data collection points.
In SCS’s release pipeline, SCS MobileTools® will include mapping and visualization functions in early 2021. SCS MobileTools® is available for download on the Apple App Store for iPhones and iPads, Google Play for Android.
The unsung hero at landfills with a landfill gas collection system is the humble Wellfield Technician. The position of Wellfield Technician is multifaceted; this individual needs to be well equipped to deal with constant changes. A good technician is capable of:
All while communicating effectively with those on their team, during all kinds of weather and changing conditions.
One practice that most good Technicians embrace is keeping effective field notes. Those not engaging in this practice should consider doing so. Field notes and comments added to a row of monitoring data can be of great future value to the technician and the rest of the team. Accurate and detailed field notes contain information that can help the project team when it comes time to diagnose, repair, or troubleshoot various wellfield issues.
Whether it’s a handwritten entry in a logbook, a comment stored in a field instrument, or notes saved in a smartphone, tablet, or computer, the information recorded in field notes is indispensable for the proper, efficient maintenance of the wellfield.
Technicians are hard-pressed to recall every detail during the hectic daily push to get the wellfield read, while multitasking and keeping up with items that pop up at a moment’s notice. By keeping track of this information through note-taking or SCSeTools®, the technician can be more efficient over time – they won’t be scratching their head, trying to remember a detail important to a task.
Examples of items we track in our database include: wellhead valve positions, surging in vacuum supply risers at wellheads, required maintenance of sample ports, flex hoses, audible wellhead leaks, ponding water around wells, surface cracks around a well, and borehole backfill material settlement.
Regardless of how recorded, save field notes as valuable points of reference.
Handwritten notes are entered into a preventative maintenance program or a wellfield database so that they are accessible for use in planning repairs or troubleshooting problems. Another option is to capture them automatically, even noting the GSI coordinates into a database such as SCSeTools, to save time and lessen transcription errors.
Once completing wellfield monitoring and tuning, technicians then use comments or notes as a punch-list to return to the wellfield − ready to perform maintenance or repairs. These are the actions that keep the landfill gas collection components operating efficiently, and clients’ happy.
About the Author: Ken Brynda is an SCS Field Services OM&M Compliance Manager in North Carolina. He is an active member of SWANA’s Landfill Gas and Biogas Technical Division, Field Practices Committee serving clients for over 30 years. Ken’s expertise includes the design, construction, operation and maintenance, evaluation, troubleshooting, and assessment of landfill gas collection and control systems and LFG-to-energy production facilities.
Learn more about Landfill Services here.
San Bernardino County’s almost 500-acre San Timoteo landfill upgraded with gas monitoring and controls that manage its four blowers, flare station, pumps, valves, thermocouples, and other devices. There are 340 tags, 16 screens and more than 50 alarms monitored and managed by web-based SCADA software. Simpler, streamlined SCADA is more capable and closely connected, and less costly for landfill gas monitoring and control.
San Timoteo added options such as 3D imaging from flying drones and augmented reality (AR) displays. After flying the site, the imagery is uploaded to update its map and create point-cloud graphics. Aerial data is used to create topographic mapping, 2D images, 3D renderings, and GIS, thermal and tunable diode laser (TDL) images for methane leak detection.
Landfill operators and managers can remotely view the site using a mobile device, and “walk the site” from their offices or anywhere using the HoloLens.
Now nearly all landfills can afford to gather data with Ethernet and wireless networking, analyze data with sophisticated software, and display it on ubiquitous interfaces including tablet PCs and smartphones. The trick is applying the technologies in applications that enable more effective decisions.
Read the article in Control Magazine.
Watch a quick video at San Timoteo.
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.
On March 26, 2020, the EPA issued the COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program memorandum. This temporary policy allows for enforcement discretion for noncompliance resulting from the pandemic. The memorandum requires regulated entities to take specific steps, then document how COVID-19 caused the noncompliance and efforts to return to compliance. Noncompliance issues may include but are not limited to, routine monitoring, reporting, and testing.
EPA is the implementing authority for programs where the consequences of the pandemic may affect reporting obligations and milestones set forth in settlements and consent decrees. These consequences may affect the ability of an operation to meet enforceable limitations on air emissions and water discharges, requirements for the management of hazardous waste, or requirements to ensure and provide safe drinking water.
These are very distinct situations that the EPA plans to manage differently, as described on the EPA website page https://www.epa.gov/sites/production/files/2020-03/documents/oecamemooncovid19implications.pdf
Not all states and commonwealths have adopted a temporary discretionary enforcement policy. As an example, the Illinois EPA has not adopted a discretionary enforcement policy, and all state statutes and regulations remain in effect. Should your organization face a situation where regulatory compliance may be at risk due to COVID-19, this special circumstance may still be a mitigating factor in the event of an enforcement action by Illinois EPA.
If you are uncertain if you will be able to meet your compliance obligations due to the COVID-19 pandemic, and you need assistance please visit our locations to find the office nearest you or contact an SCS professional at .
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 at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin summarizes the 2020 National Emission Standards For Hazardous Air Pollutants: Solid Waste Landfills. SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and a webinar with Pat Sullivan on our website and social media accounts.
2020 NESHAP Technical Bulletin.
SCS Contact Information:
Locate an SCS professional near you, or contact SCS at .
SCS will continually update coverage of this Rule on our website blog and social media channels on SCS Engineers LinkedIn and SCS Engineers Facebook. If you have any questions regarding this Technical Bulletin, feel free to contact your local SCS Engineers representative.
EPA has issued a revised NESHAP standard for municipal solid waste landfills. The new rule reflects EPA’s conclusions regarding the residual risk and technology rule, resolves confusion created when the previous rule was not updated at the same time as the landfill NSPS and updates landfill gas well head criteria for temperature. EPA is also clarifying that the standards are applicable during periods of startup, shutdown and malfunction, and requiring electronic reporting of performance test results.
This action finalizes the residual risk and technology review (RTR) conducted for the Municipal Solid Waste (MSW) Landfills source category regulated under National Emission Standards for Hazardous Air Pollutants (NESHAP) contained within 40 Code of Federal Regulations (CFR) Part 63, Subpart AAAA. Additionally, the U.S. Environmental Protection Agency (EPA) is taking final action to:
The EPA is also finalizing minor changes to the MSW Landfills NSPS and Emission Guidelines (EG) and Compliance Times for MSW Landfills contained within 40 CFR Part 60, Subparts XXX and Cf. Specifically, the EPA is finalizing provisions to the most recent MSW Landfills NSPS and EG that would allow affected sources to demonstrate compliance with landfill gas control, operating, monitoring, recordkeeping, and reporting requirements by following the corresponding requirements in the MSW Landfills NESHAP. According to EPA, these final amendments will result in improved compliance and implementation of the rule and eliminate some of the confusion created by the previous version of the EPA rule.
We’ve pulled this information from the Final Amendments to Air Toxics Standards for Municipal Solid Waste Landfills and SCS will publish an SCS Technical Bulletin on our blog and social media sites. Please contact your Project Manager for details specific to your operation.
Approximately 738 MSW landfills are subject to the NESHAP.
On February 25, 2020, EPA finalized amendments to the 2003 NESHAP for MSW Landfills. EPA issued air toxics standards for the MSW Landfills source category in 2003 that established emission limitations based on maximum achievable control technology (MACT) standards for hazardous air pollutants (HAP) from major and area sources.
The rule required MSW landfills greater than 2.5 million megagrams (Mg) and 2.5 million cubic meters with uncontrolled emissions greater than 50 Mg/year of non-methane organic compounds (NMOC) to install and operate a gas collection and control system (GCCS). Most emissions from MSW landfills come from the continuous biodegredation of the MSW. Landfill gas contains methane, carbon dioxide and more than 100 different NMOC, including, but not limited to, vinyl chloride, ethyl benzene, benzene and toluene.
Based on the RTR, EPA is finalizing no changes to the existing standards because the agency determined the risks to be acceptable with an ample margin of safety to protect public health and the environment. In addition, EPA did not identify any new cost-effective emission controls for MSW landfills. However, EPA is finalizing several minor amendments to reorganize and streamline requirements for MSW landfills that will improve the clarity, compliance and implementation of the rule. These include:
The Clean Air Act (CAA) requires EPA to regulate toxic air pollutants, also known as air toxics, from categories of industrial facilities in two phases. The first phase is “technology-based,” where EPA develops standards for controlling the emissions of air toxics from sources in an industry group or “source category.” EPA bases these MACT standards on emission levels that are already being achieved by the best-controlled and lower-emitting sources in an industry. Within 8 years of setting the MACT standards, the CAA directs EPA to assess the remaining health risks from each source category to determine whether the MACT standards protect public health with an ample margin of safety and protect against adverse environmental effects. This second phase is a “risk-based” approach called residual risk. Here, EPA must determine whether more health-protective standards are necessary.
Every 8 years after setting MACT standards, the CAA requires EPA to review and revise the standards, if necessary, to account for improvements in air pollution controls and/or prevention and to address any residual risks that still remain after the MACT is implemented.
The CAA requires EPA to assess the risk remaining after application of the final air toxics emission standards; known as a residual risk assessment. Based on the completed risk assessment, available health information, and associated uncertainties, EPA determined risks from the MSW Landfills source category are acceptable and provide an ample margin of safety to protect public health. EPA estimates the maximum individual lifetime cancer risk for inhalation for the source category to be less than 10-in-1 million.
The CAA requires EPA to assess, review and revise air toxics standards, as necessary, taking into account developments in practices, processes and control technologies. The technology review of the standards for MSW Landfills did not identify any developments that would further reduce HAP emissions beyond the original NESHAP.
Download a copy of the final rule notice from EPA’s website at the following address: https://www.epa.gov/stationary-sources-air-pollution/municipal-solid-waste-landfills-national-emission-standards.
SCS will publish an SCS Technical Bulletin on our blog and social media sites. Please contact your Project Manager for details specific to your operation.
SCS Customer Support:
800-767-4727
Local Offices or Find a Specialist
National Emission Standards for Hazardous Air Pollutants: Stationary Combustion Turbines Residual Risk and Technology Review 40 CFR Part 63
This action finalizes the residual risk and technology review (RTR) conducted for the Stationary Combustion Turbines source category regulated under national emission standards for hazardous air pollutants (NESHAP). In addition, EPA is taking final action addressing requirements during periods of startup, shutdown, and malfunction (SSM)
and to add electronic reporting requirements.
The EPA is finalizing its proposed determination that the risks from this source category due to emissions of air toxics are acceptable and that the existing NESHAP provides an ample margin of safety to protect public health. The EPA is also finalizing its proposed determination that EPA identified no new cost-effective controls under the technology review that would achieve further emissions reductions from the source category.
This final rule is effective on March 9, 2020. The incorporation by reference (IBR) of certain publications listed in the rule is approved by the Director of the Federal Register as of March 9, 2020.
For questions about this final action and electronic reporting requirements, contact:
Melanie King, Sector Policies and Programs Division (D243-01), Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, email
address: .
For specific information regarding the risk modeling methodology, contact Mark Morris, Health and Environmental Impacts Division (C539-02), Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, email address: .
For information about the applicability of the Stationary Combustion Turbines NESHAP to a particular entity, contact Sara Ayres, Office of Enforcement and Compliance Assurance, U.S. Environmental Protection Agency, email address: .
The environmental reporting season is just around the corner. Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.
Table: environmental regulatory agencies in Illinois, Indiana, and Wisconsin
The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry. Contact us at or find a professional like Ann, nearest you.
Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Thanks, Ann!
Corporate Headquarters
3900 Kilroy Airport Way Suite 300
Long Beach, CA 90806
Telephone
1 (800) 767-4727
1 (562) 427-0805 | FAX
Contact Us
