EPA updated its Compliance and Emissions Data Reporting Interface (CEDRI) for the electronic reporting of air emissions under the NESHAP related to MSW landfills. Three new reporting templates were added on October 15, 2024, each linked to its corresponding Excel spreadsheet template. These include the
The Semi-Annual report is the most significant because MSW landfills have 90 days to begin using the Excel template. Reports due January 13, 2025, or any time after that must include this electronic filing.
EPA’s color-coded template provides a bit of instruction.
The gray tab (Company Information) contains general information likely to be unchanged from report to report. After completing the gray tab, you may save the workbook as a site-specific template to use in subsequent reports to limit subsequent data entry.
Complete the green tabs (Certification, CMS Info, Description of Changes, Exceedances, and Number of Exceedances) as appropriate to complete the semi-annual report.
Complete the blue tabs (Deviation Detail, Deviation Summary, CMS Detail, and CMS Summary) if deviations or CMS out-of-control periods or downtime periods occur according to §63.10(e) and as defined in §63.1990.
The orange tabs (Well Expansion, Operational Statements, Site Specific Treatment, Enhanced Monitoring, Bypass CDT Not Operating, and Corrective Action Analysis) cover information required by the semi-annual report requirements of §63.1981(h); be sure to complete the requisite tabs.
Professionals at SCS Engineers will post more guidance but plan to continue preparing our clients’ semi-annual reports as we do now, and completing and submitting this spreadsheet. Please work with your air emissions specialist or project manager, or contact us for support.
Additional Resources:
The Environmental Protection Agency (EPA) is finalizing amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reciprocating Internal Combustion Engines (RICE), the New Source Performance Standards (NSPS) for Stationary Compression Ignition (CI) Internal Combustion Engines, and the NSPS for Stationary Spark Ignition (SI) Internal Combustion Engines, to add electronic reporting provisions.
According to EPA the addition of electronic reporting provisions will provide for simplified reporting by sources and enhance availability of data on sources to the EPA and the public. In addition, a small number of clarifications and corrections to these rules are being finalized to provide clarification and correct inadvertent and other minor errors in the Code of Federal Regulations (CFR), particularly related to tables.
Reference the Federal Register: National Emission Standards for Hazardous Air Pollutants: Reciprocating Internal Combustion Engines and New Source Performance Standards: Internal Combustion Engines; Electronic Reporting where the site covers:
For additional information, please contact SCS Engineers, or visit the Federal Register.
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.
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:
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:
We’re here to help. Please find an expert or contact us at .
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.
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.
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 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.
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 .
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:
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.
