non-methane organic compounds

October 19, 2015

SWANA Landfill Gas & Biogas Tech News, October 2015

Reprint

Leadership Note
By Patrick S. Sullivan, REPA, CPP, BCES, Division Vice Director

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:

• A definition of LFG treatment.
• Additional surface emissions monitoring (SEM) requirements.
• A new Tier 4 methodology using surface emissions monitoring to avoid or delay GCCS installation.
• Updated LFG wellhead criteria to exclude limits for oxygen and temperature.
• Additional options for removal of the GCCS in non-producing areas.
• Elimination of the Startup, Shutdown, and Malfunction (SSM) exemption contained within current versions of the rules.

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:

• GCCS Design Plans.
• Organics Diversion.
• Best System of Emission Reductions (BSER).
• Electronic Reporting.
• NMOC Test Methods.
• Waste Definitions.
• Early Collection.

During the comment period, the EPA also is looking for public comment on:

• Defining closed areas and how such areas should be regulated under the rule.
• Implementing enhanced SEM requirements.
• Defining “wet” landfills and how such landfills should be regulated under the rule.
• Monitoring LFG flow at wellhead and uses of that data.
• Third-party GCCS Design Plan certifications to relieve the burden on state/local agencies and speed up plan approvals.
• Using portable meters for compliance with U.S. EPA Methods 3A and 3C (nitrogen and oxygen).

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