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 .
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.
Landfill operators have known about elevated temperature conditions in landfills for nearly a decade. Some operators have already incurred numerous expenses to control adverse environmental and operational issues at these landfills, and some operators have set aside large amounts of money in their books to address future liabilities associated with such landfills. Due to the complexities of controlling elevated temperature conditions and the compliance issues arising from such conditions, it can force operators to temporarily, or permanently close their landfills.
Can design address elevated temperature conditions?
The operators of larger landfills have been monitoring and analyzing data to identify triggering factors, while others continue controlling the environmental impacts. Environmental Research & Education Foundation (EREF) initiated several research projects to identify the triggering factors with the excellent scientific work of highly qualified researchers. These are on-going projects.
In the meanwhile, operators of larger landfills are developing strategies, basing strategic-decisions on the data and conditions collected during operations over long periods. After analyses, they have the means to reduce the impacts by making changes in their operations and landfill designs. The most effective changes include eliminating certain waste types from the waste stream and improving the movement of liquid and gas through the waste column with new designs.
Are design innovations consistently implemented?
The pioneering designs feature preventative measures, intending to avert the formation of elevated temperature conditions in future disposal cells. Implementing these new design features requires careful consideration and functional analyses, as some of the recommendations can be costly, affecting the bottom line. The urgency in controlling compliance issues associated with elevated temperatures and the associated financial impacts of such conditions objectively prescribe that local managers work closely with their designers and field expertise to bring non-compliance issues under control.
Is this an executive risk management strategy?
Until the on-going research more clearly identifies the triggering factors and the means to prevent the development of elevated temperature conditions, it seems logical to invest in implementing preventative measures that are currently available. When more research results are accessible, then the local managers will be able to make decisions that are even more informed. Those wanting to address the likelihood of future liabilities proactively will need executive-level funding and superior technical support, all of which are possible.
Is there much sharing of newer designs and strategies within the solid waste industry?
Yes, there is a fair amount of collaboration among the technical community and within solid waste associations. Most operators share their preventative designs within the engineering community and help contribute to funded research. Their actions and results will help to strengthen an industry application until such time that research results and the means to prevent the development of elevated temperature conditions are well understood. We all know that progress in technology and science depends on sharing new knowledge.
Let’s continue with the combination of serious research, innovative designs, proactive operational changes, and sharing knowledge among our industry professionals that will lead to more precise solutions in the near future. Here are a few resources available now:
About the Author: Ali Khatami, Ph.D., PE, LEP, CGC, is a Project Director and a Vice President of SCS Engineers. He is also our National Expert for Elevated Temperature Landfills, plus Landfill Design and Construction Quality Assurance. He has nearly 40 years of research and professional experience in mechanical, structural, and civil engineering.
Learn more at Elevated Temperature Landfills
EPA’s Interpretation of “Begin Actual Construction” Under the New Source Review Preconstruction Permitting Regulations
This EPA guidance addresses EPA’s interpretation of when an owner or operator must obtain an NSR permit for a major stationary source or major modification before the start of actual construction on the facility. Currently, EPA considers almost every physical on-site construction activity that is of a permanent nature to constitute the beginning of “actual construction,” even where that activity does not involve construction “on an emissions unit.”
The interpretation fails to give meaning to the distinction between an emissions unit and a major stationary source. As such, it tends to prevent source owners/operators from engaging in a wide range of preparatory activities they might otherwise desire to undertake before obtaining an NSR permit. For this reason, EPA is adopting a revised interpretation that is more consistent with the regulatory text.
The proposed revised interpretation will stipulate that a source owner or operator may, prior to obtaining an NSR permit, undertake physical on-site activities – including activities that may be costly, that may significantly alter the site, and/or are permanent in nature – provided that those activities do not constitute physical construction on an emissions unit.
Begin actual construction means, in general, initiation of physical on-site construction activities on an emissions unit, which are of a permanent nature. Such activities include, but are not limited to, installation of building supports and foundations, laying underground pipework and construction of permanent storage structures.
EPA does not find it plausible that NSR permit applicants undertaking significant on-site construction activities prior to permit issuance will allow them to gain leverage with respect to the outcome of the permitting process. Stationary source owners or operators cannot expect that any site activities prior to permitting will alter or influence the BACT analysis for an emissions unit or other elements of a permitting decision. Permit applicants that choose to undertake on-site construction activities in advance of permit issuance do so at their own risk.
EPA is providing an opportunity for interested stakeholders to review and comment on the draft guidance titled, Interpretation of “Begin Actual Construction” Under the New Source Review Preconstruction Permitting Regulations through May 11, 2020. For any questions concerning this memorandum, please contact Juan Santiago, Associate Division Director of the Air Quality Policy Division, Office of Air Quality Planning and Standards at (919) 541-1084 or .
Read the draft guidance: Interpretation of “Begin Actual Construction” Under the New Source Review Preconstruction Permitting Regulations
Submit comments using the form at . EPA will consider the comments received and complete a revised version of the guidance.
More information at Clean Air Act Services or Oil & Gas Permitting
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Lessons learned from previously constructed gas collection and control systems teach solid waste professionals valuable lessons about designing for long-term survivability and reducing the maintenance cost of gas system components. The location impacts operating and maintenance costs for various components of gas collection and control systems such as condensate force main, condensate sumps, force main for well liquids, air lines to pumps in gas wells, and gas headers long into the future. As often as possible, design the gas header in the landfill perimeter berm along with the condensate sumps. Landfill perimeter berms constructed in an engineered manner with well- compacted soils and a well-defined geometry provide a long-term cost-effective alternative to earlier designs outside the berm.
For many years, gas headers were designed and constructed outside of the landfill perimeter berm, on the landfill surface. Of course, landfill surface changes as waste elevation increases over time, resulting in many gas headers that now may be 30 feet or more below the current waste surface. Deeply buried gas headers are unreliable at best, and the operator loses access to them as soon as 20 feet of waste covers the header.
Collapsed gas headers buried deep in waste are an expensive challenge when operating a large number of gas wells connected to the gas header, and could cause serious compliance issues. Upon discovery of a collapsed buried gas header, installing a new header is a lengthy process with significant costs, not to mention the hurdles the operator will have to jump addressing noncompliance with their state agency.
The benefits of placing gas headers in the landfill perimeter are:
Since the condensate force main follows the gas header in the perimeter berm to flow to a tank or discharge point, there are additional maintenance benefits.
By continuing to design gas header construction on landfill slopes, all of the components end up on the landfill slope as well. You can imagine what type of complications the landfill operator will face since all of these components are in areas vulnerable to erosion, settlement, future filling or future construction. Additionally, any maintenance requiring digging and re-piping necessitates placing equipment on the landfill slope and disturbing the landfill slope surface for an extended period.
For more information about these benefits and more, please refer to the MSW Magazine article series Considerations for the Piping Network, the author, or contact SCS Engineers at .
About the Author: Ali Khatami, Ph.D., PE, LEP, CGC, is a Project Director and a Vice President of SCS Engineers. He is also our National Expert for Landfill Design and Construction Quality Assurance. He has nearly 40 years of research and professional experience in mechanical, structural, and civil engineering.
Learn more at Landfill Engineering
REPRINT OF USEPA PRESS RELEASE
WASHINGTON (Dec. 3, 2019) — Today, the U.S. Environmental Protection Agency (EPA) is announcing several actions to clarify and improve New Source Review (NSR) permitting requirements. These Clean Air Act actions are part of a suite of measures EPA is taking to modernize and streamline the NSR process, without impeding the Agency’s ongoing efforts to maintain and enhance the nation’s air quality. These actions will improve regulatory certainty and remove unnecessary obstacles to projects aiming to improve the reliability, efficiency, and safety of facilities while maintaining air quality standards.
“NSR reforms are a key component of President Trump’s agenda to revitalize American manufacturing and grow our economy while continuing to protect and improve the environment,” said EPA Administrator Andrew Wheeler. “NSR regularly discouraged companies from investing in and deploying the cleanest and most efficient technologies. Through the Trump Administration’s efforts, EPA is providing clarity to permitting requirements, improving the overall process, and incentivizing investments in the latest energy technologies.”
“For too long, New Source Review permitting requirements stifled job creation, hampered innovation and slowed the ability to modernize critical energy infrastructure. Worse, in previous administrations, the permits were weaponized, so liberal activists could delay key projects,” said U.S. Senator Jim Inhofe (OK). “New Source Review hasn’t been updated in over four decades—making it hard to integrate new technologies into our energy infrastructure. I’ve worked for years to modernize the review process, and applaud today’s action by President Trump and Administrator Wheeler to streamline the NSR permitting process.”
“One of my consistent frustrations with New Source Review is what seems to be a perverse incentive away from innovation. Thank you to Administrator Wheeler and the Trump Administration for recognizing this and finalizing these positive reforms,” said U.S. Senator Kevin Cramer (ND). “The EPA’s actions provide certainty while restoring the proper scope of the Clean Air Act.”
“I applaud the EPA for taking further steps to reform the New Source Review permitting program. NSR’s burdensome process can impede upgrades that would actually increase efficiency and improve air quality. The EPA is moving toward a better NSR program that streamlines the process without sacrificing environmental protections,” said U.S. Representative Morgan Griffith (VA-09).
“I applaud Administrator Wheeler for implementing a strong regulatory reform agenda at the EPA. Today’s actions are a solid first step in the right direction to reform the NSR permitting program. I look forward to continue working with the Trump Administration to further reform NSR and allow America’s industry to make their units more reliable and efficient, while maintaining strong environmental standards,” said U.S. Representative Andy Biggs (AZ-05).
“President Donald Trump continues to deliver on his promise to cut burdensome regulations that strangle American manufacturing and energy development. These improvements to the New Source Review (NSR) permitting requirements will protect our air quality, while incentivizing businesses to grow and expand. I look forward to continuing to work with President Trump and Administrator Wheeler to cut needless regulations and create American jobs,” said U.S. Representative Alex X. Mooney (WV-02).
“This Administration is clearing the path for manufacturers to invest in more energy efficient technologies that conserve energy, reduce emissions, and keep U.S. manufacturers competitive,” said Portland Cement Association President and CEO Mike Ireland. “For energy-intensive industries like cement, strategic investment in energy efficiency and emissions reduction are key components of any long-term climate and sustainability strategy, and EPA’s New Source Review reforms announced today help unlock new opportunities for sustainable operation.”
Final Guidance: Revised Policy on Exclusions from “Ambient Air”
After considering public comments, EPA is issuing final guidance, identifying the sort of measures which EPA may take account of in determining whether a source owner or operator has precluded the general public from having access to its property. Where access is precluded, the portion of the atmosphere above that property is not considered “ambient air” for the purpose of conducting air quality analyses under the Clean Air Act. The guidance updates EPA’s policy to recognize that a variety of measures may be considered effective in keeping the public off a source owner/operator’s property. These measures, which account for advances in surveillance and monitoring, depend on site-specific circumstances and continue to include, but are now not solely limited to, fences or other physical barriers. State, local and tribal permitting authorities have the discretion to apply this guidance on a case-by-case basis. The regulatory definition of “ambient air,” as stated in 40 CFR § 50.1(e) to mean “that portion of the atmosphere, external to buildings, to which the general public has access,” remains unchanged.
Final Guidance: Interpreting “Adjacent” for New Source Review and Title V Source Determinations in All Industries other than Oil and Gas
EPA has also recently issued a final guidance that revises the agency’s interpretation of when multiple air pollution-emitting activities are located on sufficiently “adjacent” properties to one another that they should be considered a single source for the purposes of permitting. To determine what activities comprise a single source under the NSR and Title V air permitting programs, three factors must be satisfied: the activities must be under common control; they must be located on contiguous or adjacent properties; and they must fall under the same major group standard industrial classification (SIC) code. In this guidance, for all industries other than oil and natural gas production and processing for which there is a separate set of rules and to which this guidance does not apply, EPA adopts an interpretation of “adjacent” that is based on physical proximity only. The concept of “functional interrelatedness” would not be considered by EPA when determining whether activities are located on adjacent properties. This interpretation should help clarify and streamline the permitting process.
Additional NSR Proposals
EPA also recently issued a proposal to address minor errors that have accumulated over time in four NSR regulations. While these minor errors, such as outdated cross references and typographical errors, have not materially impeded the effective operation of the NSR program, EPA believes that it is important to remove such errors from the regulations in order to provide regulatory certainty and clarity. The proposed corrections are all considered to be non-substantive and are intended to provide clarity and precision to the NSR regulations without altering any NSR policy or changing the NSR program as a whole.
EPA is also proposing to remove from the NSR regulations various provisions, such as certain “grandfathering” provisions, that, with the passage of time, no longer serve any practical function or purpose. EPA will be taking comment on this proposal, which will be published in the Federal Register.
More information on these actions and other NSR improvements are available at: https://www.epa.gov/nsr
Coming Soon: Revisions to Petition Provisions of Title V Permitting Program
EPA is currently working to take final action on a 2016 proposal for revisions to the title V regulations. This proposal would streamline and clarify processes related to the submittal and review of title V petitions.
The proposed rule would bring more certainty for all stakeholders, including the sources required to obtain and maintain title V permits; more focused petitions; better title V permit records which are expected to result in fewer petitions; and reduced administrative burden in the EPA’s review of petitions in a tight timeframe.
Background
Congress established New Source Review as a preconstruction permitting program in the 1977 Clean Air Act Amendments. The program intended to ensure the maintenance of air quality standards around the country and that state of the art technology is installed at new plants or existing plants undergoing major modifications.
Under the NSR program, before constructing a new stationary emission source or major modification of an existing source, the source operator must determine whether the new source will emit or the project will increase air emissions above certain thresholds. If so, the operator may need to get a permit from a state government or EPA that may require installation of pollution control technology or other measures.
Contract your SCS project manager, or if you have questions about the impact of these recent actions.
Before the Court: EPA admits that it has failed to meet its nondiscretionary obligations to implement the Landfill Emissions Guidelines, as compelled by the CAA. The only questions before the Court were whether the Plaintiffs have standing and, if so, how long to give EPA to comply with its overdue nondiscretionary duties under the Landfill Emissions Guidelines. The Plaintiffs are the States of Illinois, Maryland, New Mexico, Oregon, Rhode Island, California, Vermont, and the Commonwealth of Pennsylvania.
Ruling: Plaintiffs have standing, and the EPA must approve existing submitted plans by September 6 and issue the federal plan by November 6.
Impact on Landfill Owners/Operators: This will create some confusion, as landfills will be working on getting revised rules in place while at the same time start complying with the old EG rule. We are already doing that with XXX sites, but this ruling adds complexity. If EPA keeps to the schedule and we have final approved revised rules by March 2020, landfills won’t have to do as much under the old rules before new ones take effect.
Contact your SCS Project Manager for more information, email us at , or follow SCS on your preferred social media.
To generate a return on investment of site-specific GCCS, you need OMM staff who understand the strengths and weaknesses of your site. From that understanding, successful OMM teams and facility owners can design, perform, and fine-tune their program.
SCS’s BMP’s uses a “beyond the compliance OMM model” because the practice leads to strengthening relationships with regulatory agencies and LFG energy providers. Our clients expect to move toward a field optimization program when both OMM procedures and regulatory requirements are fine-tuned to work in concert. That investment pays dividends by increasing compliance and improving gas recovery. When developed OMM principles are defined clearly, and evolved along with GCCS design and construction, teams rise to the challenge, and the reward is a consistent track record of excellent GCCS operation.
Part 1 of the series discusses design considerations for landfill gas collection and control systems (GCCS); Part 2 takes into account construction quality assurance (CQA) measures during construction of GCCS; and Part 3 covers BMP’s for GCCS Operation, Monitoring, and Maintenance (OMM) in the September/October issue of MSW Magazine. The SCS Team covers:
A look at the confusion stemming from regulatory uncertainty of new rules limiting air emissions from municipal solid waste landfills by David Greene, P.E., SCS Engineers – Asheville, NC.
The landfill industry continues to work with EPA Administration to get a longer-term stay to work out needed NSPS/EG rule changes. At this time, industry representatives are hopeful both these related goals can be achieved.
While the new NSPS/EG rules became effective back in 2016, the concerns with the rules raised at the time still remain unresolved. Despite this, we can expect resolution though it may take some time to fix. The fog should be lifting, yielding changes that are expected to be more workable for both the landfill industry and state/local regulators. In the meantime, stay tuned and stay informed.
Read the full article with links to the NSPS/EG update in a recently published SCS Technical Bulletin.
SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. Our most recent SCS Bulletin summarizes the new rules which took effect on October 28, 2016, with compliance obligations under the NSPS Subpart XXX rule beginning November 28, 2016. Originally, states and local air jurisdictions were to submit their proposed EG rules by May 30, 2017; however, there have been some delays in this process, which we condense and detail in this Bulletin. SCS will continually update coverage of this Rule on our website.
