Reprint
The SWANA Landfill Gas and Biogas Division is very busy right now with several important efforts. On the Rules and Regulations front, the U.S. EPA has promulgated two draft landfill gas (LFG) rules that were published in the Federal Register on August 27, 2015. These include a draft Emission Guideline (EG) rule and a supplemental draft New Source Performance Standards (NSPS) rule.
The proposed EG rule affects “existing” landfill sites (i.e., landfills that have not been expanded and were not newly constructed after July 17, 2014). The NSPS rule is a supplemental proposal that affects “new” landfill sites (landfills that are new or were expanded in capacity after July 17, 2014). Comments on both are due by October 26, 2015. Final issuance of both rules is expected in the first quarter of 2016. The Division Rules and Regulation and Advocacy committees are working together to develop SWANA’s industry comments on the rules.
The major focus of both rules is the current 50 Mg/year of non-methane organic compounds (NMOCs) emission threshold, which triggers the installation of a LFG collection and control system (GCCS). In the proposed rules, that threshold will be lowered to 34 Mg/year for all landfills except existing, closed sites. This appears to be the centerpiece of the U.S. EPA’s plan to create additional NMOC and methane reductions from landfills. With a lowered NMOC threshold, some landfills, particularly those that have been too small to trigger the installation of a GCCS, will be required to install them.
Other key components of the draft EG rule, which are likely to be similar in the NSPS rule, include the following:
The draft EG rule also provides clarifications on several existing rule topics, as well as topics where U.S. EPA decided not to include such items in the rule:
During the comment period, the EPA also is looking for public comment on:
The EPA will have the ability to add more provisions to the final version of the rule based on the information submitted as a part of these information requests. This means the industry must make a strong case to the EPA to get them to consider our opinions on these issues.
Comments on this article should be addressed to Patrick S. Sullivan, Senior Vice President, SCS Engineers, at 916-361-1297 or
SALT LAKE CITY, UT. – SCS Engineers recently announced the opening of a new office near Salt Lake City, expanding services to clients in the Western region of the U.S. The new office is located at:
SCS Engineers | SCS Field Services
1952 West Parkway Boulevard,
West Valley City, UT 84119
Tel: +1-801-849-2160
SCS continues to provide environmental engineering and consulting services to municipal and private sector clients, and has expanded the range of its SCS Field Services Division to provide clients in Nevada, Utah, Colorado, and Montana with a variety of landfill, landfill gas (LFG), and landfill gas to energy (LFGTE) services, including LFG collection and control system operations, monitoring, and maintenance services.
SCS also offers SCSeTools®, a platform for data management software used at landfills to improve operational safety, data collection, and analysis to meet the new EPA compliance rule. SCSeTools currently features SCS DataServices®, SCS Remote Monitoring and Control®, and SCS MobileToolsTM and is in use at over 600 landfills nationwide. The unique combination of high-level technical engineering services with practical, hands-on operations expertise, including compliance data management is not typically available from other environmental engineering firms.
“Our intent is to continuously expand our support to clients in these states,” said Galen Petoyan, Senior Vice President of SCS Field Services OM&M Division. “We continue to use highly-skilled professionals with plenty of field experience, and our ability to analyze a landfill’s data has helped us become even more dependable and cost-effective on closed and active landfills.”
