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.
As a designer, I’ve been hired to correct inconsistencies between the gas system and the landfill too many times. Today’s blog is about the most important factors that all landfill gas designers should consider for a gas system to coordinate efficiently with the landfill design as permitted. This is a partial list of best practices developed at SCS Engineers.
Considerations for Design of Gas Collection Systems for Landfills:
1. Include the final cover layers in the gas design details where gas wells are installed near the landfill final surface. This inclusion will help the designer to specify proper heights for gas wells, proper depths for gas headers and lateral pipes, and proper heights for condensate sumps within the lined area of the landfill. Otherwise, locations of these elements may end up being in conflict with the location of various layers of the final cover system to be constructed later.
2. Always leave pipes exiting the liner boundary at the perimeter of the landfill at least 1 ft above the anchor trench shoulder. When the final cover is installed, it would be impossible to install a geomembrane boot over at the cover geomembrane penetration point of a pipe that is in contact with the bottom lining system geosynthetics over the anchor trench shoulder.
3. If flow control valves are located below the final cover near the perimeter of the landfill, design a vertical casing around the valve tall enough that future final cover can be booted to the vertical casing and access to the valve would be possible. Do not use corrugated material as casing because it would be difficult to place a geomembrane boot over corrugated casings. The designer should require sealing the void inside the casing pipe to prevent landfill gas release or oxygen intake through the void. If the control valve is located above the final cover, the designer should specify a proper height for the casing pipe that access to the valve stay above the final cover surface.
4. Locating flow control valves near the landfill perimeter and within the lined area should be in consideration with the future location of a rainwater toe drain system at the toe of the slope that will be constructed when the final cover is constructed.
5. Condensate sumps installed before construction of the final cover should be tall enough to accommodate construction of the final cover system around the condensate sump with sufficient space to boot the final cover geomembrane to the exterior walls of the condensate sump. Miscellaneous stub outs on the condensate sump should be designed in consideration of having enough space for the geomembrane boot in the future.
6. Pipes connected to a condensate sump (such as compressed air line, discharge force main, power conduits, etc.) should be positioned such that boots can be placed on each line at the penetration point of the pipe through the final cover geomembrane. Boots may not be placed on pipes clustered together. If boots are placed on a pipe cluster, the designer should require sealing the voids between the pipes within the boot to prevent landfill gas release or oxygen intake through the voids.
7. Gas pipes located above the final cover geomembrane and crossing terraces on landfill side slopes may create conflict with rain water toe drain at the terrace. The designer should design terrace crossings such that future conflicts can be avoided.
8. Gas pipes crossing an access road on the landfill slope may cause conflict with a ditch adjacent to the access road at the final cover surface. Location of the gas pipes, either below or above the final cover geomembrane, should be designed in consideration of the final cover features that will exist in the crossing area in the future.
9. Gas pipes located above the final cover geomembrane and crossing an access road on the landfill slope may cause a conflict with a rainwater toe drain system above the final cover geomembrane running parallel to the access road at the toe of the slope next to the access road.
10. Gas pipes located above the final cover geomembrane and crossing the access road on the landfill slope may cause road grade problems at the final surface. Specific depressions across the access road width may have to be designed for larger pipes to prevent grades problem at the finish surface.
11. Gas pipes located above the final cover geomembrane may cause conflict with storm water downchutes that will be installed above the final cover geomembrane. Special depressions may have to be designed to place downchutes below gas pipes on the slope. Placing gas pipes above downchute may cause a problem with the flow of condensate in the line.
12. Sometimes horizontal gas collection pipes come out of the landfill side slopes and extend down the slope to a gas header or some other component of the gas system. If the pipe segment on the slope is going to be below the final cover geomembrane, then it must be placed deeply enough in the waste that it would not have any conflict with the final cover system components, such as leachate toe drain systems, terraces, access road ditches, etc. If the pipe segment is going to be above the final cover geomembrane, extension of the horizontal pipe connecting to the pipe segment on the slope will be designed such that the horizontal pipe can penetrate the final cover geomembrane and extend down the slope while located above the final cover geomembrane. Extension of the pipe on the slope above the final cover geomembrane should not cause any conflict with the final cover components, such as rainwater toe drains at terraces or at the toe of the slope next to the perimeter berm, downchute pipes, terrace or access road grades, etc. The elbow at the connection of the horizontal pipe to the pipe segment on the slope and above the cover geomembrane is critical because a geomembrane boot must be installed at the penetration point.
13. If tack-on swales are used on the landfill slopes, gas pipes on top of the final cover geomembrane may cause conflict with the flow line inside the tack-on swales. Large headers should cross tack-on swales at the high-end point of adjacent swales to prevent flow problems in the swale.
14. If tack-on swales are used, the location of wells for drilling purposes should be chosen to be outside the tack-on swale structure.
15. If a gas header located above the final cover geomembrane and crossing a terrace or access road where the terrace or access road is sloping toward the landfill, condensate flow through the gas header may become an issue. Special depressions across the terrace or access road may need to be designed such that condensate can flow in the proper direction.
SCS Engineers is a leader in the design of landfill gas and landfill lining and final cover systems. We evaluate these issues and many others during our landfill gas design work; our clients pay only once for construction of the system and do not have to spend additional money in the future to fix a system that could have been constructed correctly in the first place. Learn more here.
Dr. Khatami has acquired extensive experience and knowledge in the areas of geology, hydrogeology, hydrology, hydraulics, construction methods, material science, construction quality assurance (CQA), and stability of earth systems. Dr. Khatami has applied this experience in the siting of numerous landfills and the remediation of hazardous waste contaminated sites.
Dr. Khatami has been involved with the design of gas management systems, hazardous waste impoundments, storage tank systems, waste tire processing facilities, composting facilities, material recovery facilities, landfill gas collection and disposal systems, leachate evaporator systems, and liquid impoundment floating covers. He has also been involved in the design and permitting of civil/environmental projects such as surface water management systems, drainage structures, municipal solid waste landfills, hazardous solid waste landfills, low-level radioactive waste landfills, leachate and wastewater conveyance and treatment systems.
Contact Dr. Khatami directly to answer questions and comments.