A Facility’s Perspective into a Modeled PSD Increment Violation
Midwest Environmental Compliance Conference – MECC 2019
In 2005, dispersion modeling was conducted in Nebraska Bluff Road Landfill as part of the construction permitting process for the Lincoln Electric System Salt Valley Generating Station. The modeling results identified a Prevention of Significant Deterioration (PSD) increment violation at the Bluff Road Landfill resulting from activities associated with landfill operations. The model results predicted an increment violation for particulate matter less than 10 microns (PM10) at the landfill boundary, specifically for the short term 24-hour standard for PM10.
This SCS Engineers’ presentation by Tia Jeter, focuses on the experience of Bluff Road Landfill and the City of Lincoln, as the entities responded to the modeled violation, and provides highlights of the process required to ultimately resolve the increment violation and bring the facility into modeled compliance with the increment.
Resolving the modeled increment violation required coordination with multiple entities, including the local air permitting authority, the Lincoln Lancaster County Health Department (LLCHD), the Nebraska Department of Environmental Quality (NDEQ) and US EPA Region 7. To resolve the violation, facility emission processes, operational limitations, emission controls, model setup, and the compliance boundary was evaluated and revised numerous times. Initial modeling efforts conducted as part of the response utilized the Industrial Source Complex 3 Short Term (ISC3ST) model, which was the EPA-approved dispersion model at the outset of the project. Due to the prolonged timeline of the project, the final compliance modeling scenario submitted to the regulatory agency was completed using AERMOD which is now the EPA-approved dispersion model.
Along the path to compliance there were multiple challenges, including negotiations on emission point modeling methods, clarification on the definition of ambient air as it relates to leased property, the requirement to create federally enforceable compliance requirements, the slow response and feedback from the regulatory authority (ies), and the bureaucratic “hold-up” of other facility projects until resolution of the violation was attained.
Tia’s presentation will provide an overview of the road to compliance for the Bluff Road Landfill from the beginning of the project to the resolution of the increment violation. Her presentation provides an insight into what other facilities may experience in the future as compliance with the National Ambient Air Quality Standards and PSD increment for PM10 and particulate matter less than 2.5 microns (PM2.5) becomes increasingly more scrutinized. Learn more about Tia Jeter.
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.