NESHAP

EPA Alternative Test Method for NESHAP MSW Landfill CO Monitoring in Landfill Gas Wells Approved | SCS Engineers

September 15, 2021

 

Approved
The EPA issued a newly approved alternative test method (ALT-143) for compliance with the enhanced monitoring provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for MSW Landfills (40 CFR 63 Subpart AAAA updated March 26, 2020). The approved alternative method instead of Method 10 allows for direct monitoring of CO at a landfill gas well using a portable gas analyzer. The NESHAP requires weekly monitoring of CO at the landfill gas well if the gas temperature is over 145F and the regulatory agency has approved no higher operating value under the NSPS/EG rules or NESHAPs. The Solid Waste Working Group (SWWG) coordinated with landfill gas meter manufacturers (QED, Elkins Earthworks) to prepare this method.

EIL approved sharing a flow chart and Excel file that can be used for monitoring/documentation purposes when using this approved alternative “field instrument method.” Don’t hesitate to get in touch with your SCS air emissions/compliance expert or contact us at for details.

EPA will post the alternative test method to the Broadly Applicable Approved Alternative Test Methods | US EPA website page. Take note that the hyperlink in EPA’s letter is out of date.

Pending Approval
The Solid Waste Working Group (SWWG) also submitted two alternative methods in lieu of Method 10 to EPA for approval using grab sample (canister, foil bag) and laboratory analysis, one with GC/FID and the other GC/TCD instrumentation. The SWWG coordinated with several national laboratories on the methods. EPA is completing its review of the two proposed methods, anticipating EPA approval before September 27, 2021, the effective date of the enhanced monitoring provisions.

 

 

 

 

 

Posted by Diane Samuels at 4:53 pm

Summer of Compliance – Articles, Videos, and Expert Advice at Your Fingertips

July 26, 2021

 

The EPA  and, in some cases, states are rolling out new emissions guidelines at least as stringent. The EPA estimates that the plans could cover about 1,600 landfills. These landfills are in 41 states, tribal entities, and the U.S. territories of Puerto Rico and the Virgin Islands.

MSW landfills without Gas Collection and Control Systems (GCCS) that reach a specific threshold will need to add these systems and have 30 months to install or update control systems to meet new standards.  As you’ve noticed by now, we’ve greatly oversimplified what is happening.

The new regulations and timetables are difficult to understand and untangle. SCS Engineers, in concert with SCS Field Services, have prepared resources to help during the transition period and afterward when landfills are likely to need more monitoring and measurement, thus creating millions of more bits of data to store, analyze, and report.

We hope you find these resources useful. We will be publishing more soon.

These resources may help you with future monitoring and maintenance:

  • VideoUsing GIS Technology on Landfills for efficient monitoring, maintenance, and compliance.
  • Waste Today Article: Landfill Operators discuss using eTools, a web-based application platform for landfill gas data.
  • EM Magazine: Remote Monitoring and Control and SCADA on landfills

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

NESHAP and NSPS/EG Transition Resources On-Demand at SCS Engineers

July 16, 2021

OOO, AAAA, NSPS, EG, and NESHAP alphabet soup.

 

Thank you to the many folks attending SCS’s live webinar on July 15th about managing the NESHAP, NSPS/EG transition period. As promised, we’ve created a library of resources for you to use and share with your colleagues.

 

These resources may help you with future monitoring and maintenance:

  • Video: Using GIS Technology on Landfills for efficient monitoring, maintenance, and compliance.
  • Web page: SCSeTools is a web-based application platform that collects, monitors, views, charts, graphs, and manages data.
  • Find an Expert: Search feature on our website to find assistance with the service area Clean Air Act.

 

We’re here to help. Please find an expert or contact us at .

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 4:33 pm

SCS Client Webinar – Compliance During the NSPS/EG and NESHAP Transition Period – July 15, 1:30 pm EASTERN

July 15, 2021

THIS LIVE EVENT WAS RECORDED ON JULY 15, 2021

The EPA’s published clarifications, technical revisions, and new rule versions for the National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for MSW landfills may feel like alphabet soup right now.

SCS Engineers’ webinar and open Q/A forum live on July 15, 2021, at 1:30 Eastern is free and could help keep you informed and on track for compliance by September 27, 2021.

Our panelists advise on the essential key information, deadlines, and changes to field operations to address during the transition from the old to the new NESHAP and NSPS rules.

  • Surface emissions monitoring;
  • Wellhead monitoring and corrective action requirements;
  • Delegation of authority to the state, local, or tribal agencies for emission standards;
  • Applicability of the General Provisions under 40 CFR 63, Subpart A to affected landfills;
  • Monitoring data for control devices during startup, shutdown, and malfunctions (SSM);
  • Gas collection and control system installation;
  • Compliance timing and reporting;
  • Open question and answer throughout the webinar.

 

View Compliance During the NSPS/EG and NESHAP Transition Period Now

Posted by Diane Samuels at 1:30 pm

What landfills need to do to transition to Federal Landfill Air Regulations…

July 7, 2021

The EPA’s published clarifications, technical revisions, and new rule versions for the National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for MSW landfills may feel like alphabet soup right now.

SCS Engineers’ upcoming webinar and open Q/A forum on July 15, 2021, at 1:30 Eastern Time is free and could help keep you informed and on track for compliance by September 27, 2021.


Our panelists will advise on the essential key information, deadlines, and changes to field operations to address during the transition from the old to the new NESHAP and NSPS rules.

• Surface emissions monitoring;
• Wellhead monitoring and corrective action requirements;
• Delegation of authority to the state, local, or tribal agencies for emission standards;
• Applicability of the General Provisions under 40 CFR 63, Subpart A to affected landfills;
• Monitoring data for control devices during startup, shutdown, and malfunctions (SSM);
• Gas collection and control system installation;
• Compliance timing and reporting;
• Open question and answer throughout the webinar.

 

REGISTER for Compliance During the NSPS/EG and NESHAP Transition Period

 

 

 

 

Posted by Diane Samuels at 6:00 am

The Alphabet Soup of New NSPS/EG and NESHAP Regulations Explained – In Time for Deadlines

July 1, 2021

nsps
Register for SCS Engineers’ free webinar on July 15, at 1:30 pm EASTERN TIME.

 

The EPA’s published clarifications, technical revisions, and new rule versions for the National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for MSW landfills may feel like alphabet soup right now.

SCS Engineers’ upcoming webinar and open Q/A forum on July 15, 2021, at 1:30 Eastern is free and could help keep you informed and on track for compliance by September 27, 2021.


Our panelists will advise on the essential key information, deadlines, and changes to field operations to address during the transition from the old to the new NESHAP and NSPS rules.

• Surface emissions monitoring;
• Wellhead monitoring and corrective action requirements;
• Delegation of authority to the state, local, or tribal agencies for emission standards;
• Applicability of the General Provisions under 40 CFR 63, Subpart A to affected landfills;
• Monitoring data for control devices during startup, shutdown, and malfunctions (SSM);
• Gas collection and control system installation;
• Compliance timing and reporting;
• Open question and answer throughout the webinar.

 

REGISTER for Compliance During the NSPS/EG and NESHAP Transition Period

 

 

 

 

Posted by Diane Samuels at 10:38 am

Landfills under the NESHAP air program must comply with updated federal regulations by September 2021

May 27, 2021

 

All landfills regulated under the NESHAP air program must comply with updated federal regulations by September 2021, including new requirements for landfill gas beneficial use treatment systems and gas system design plans. Additionally, the EPA is finalizing a federal plan implementing new NSPS air rules for landfills modified or constructed before July 2014, and not yet covered under an approved state plan.

At the state level, as part of a continued focus on greenhouse gas (GHG) reduction, Maryland MDE is expected to publish new regulations this year addressing landfill methane control.

Jacob ShepherdJacob Shepherd, P.E., will cover what landfills need to do to comply with the updated federal regulations and will discuss anticipated new requirements under the MDE regulatory initiative as an example of the direction states are moving.

This discussion takes place at REVISION 2021, an online conference.

For additional information, see our recent blog: Regulatory Alert: MSW Landfills Federal Plan to Implement the Emission Guidelines (EG) and Compliance Times.

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

Pandemic Regulatory Flexibility – EPA’s Enforcement and Compliance Assurance Program

April 23, 2020

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 .

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

SCS Technical Bulletin Posted: 2020 NESHAP – Solid Waste Landfills

April 15, 2020

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:

  • Patrick Sullivan, Senior Vice President and National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS)
  • Bob Gardner, Senior Vice President Solid Waste

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.

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills Residual Risk and Technology Review – Final NESHAP Rule

April 7, 2020

neshap aaaaEPA 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.

EPA Summary

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:

  • Correct and clarify regulatory provisions related to emissions during periods of startup, shutdown, and malfunction (SSM)
  • Revise wellhead operational standards and corrective action to improve effectiveness and provide compliance flexibility
  • Reorganize rule text to incorporate provisions from the New Source Performance Standards (NSPS) within this subpart
  • Add requirements for electronic reporting of performance test results.

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.

This final rule became effective on March 26, 2020.

 

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.

Actions:

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:

  • Overall NESHAP reorganization to reduce overlapping applicability and to promote consistency with the 1996 and 2016 NSPS and EG
  • Regulatory text for the 2016 NSPS/EG that allows affected sources to demonstrate compliance with the applicable sections of the rules by “opting in” to the operating, compliance and monitoring provisions of the NESHAP
  • Revisions to the GCCS wellhead temperature operating standard and the associated procedures for enhanced monitoring
  • Requirements for submitting electronic copies of compliance reports, including performance test results
  • Updated regulatory language for periods of startup, shutdown, and malfunction to be consistent with recent court decisions and a work practice standard for the periods when the GCCS is not operating
  • Residual Risk and Technology Review

 

Background

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.

 

Residual Risk Assessment

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.

 

Technology Review

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.

 

For Additional Information

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.

Clean Air Act Services

SCS Customer Support: 

800-767-4727

Local Offices  or  Find a Specialist

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am