NSPS

November 2, 2015

Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.
Transparency initiatives established by EPA as part of its Next Generation Compliance initiative mean increased reporting and recordkeeping for refineries.

The U.S. Environmental Protection Agency (EPA) issued a final rule on September 29, 2015, seeking to further control emissions of hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) from petroleum refineries.

This action finalizes the residual risk and technology review conducted for the petroleum refinery source category regulated under the National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR Part 63, Subpart UUU), including the refinery Maximum Achievable Control Technology Standard (MACT) 1 and Refinery MACT 2.

Click here to read the Technical Bulletin 

Posted by Diane Samuels at 2:10 pm

November 2, 2015

landfill-webinar-scs-engineersOn Monday, October 27, 2015, the Solid Waste Association of North America–SWANA and the National Waste & Recycling Association– NWRA submitted joint comments to the U.S. Environmental Protection Agency– EPA on the proposed revisions of the Emissions Guidelines– EG and Compliance Times for Municipal Solid Waste Landfills and to the supplemental proposal to the Standards of Performance for Municipal Solid Waste Landfills.

SCS Engineers has also submitted comments pertaining to the proposed EG and compliance revisions to the EPA. SCS leaders are involved in many outreach activities to help landfill owners and operators understand and prepare for the impact of the proposed modifications.

Contact SCS Engineers at for more information, or visit the SCS website for upcoming events and pertinent resources.

Posted by Diane Samuels at 6:00 am

October 19, 2015

SWANA Landfill Gas & Biogas Tech News, October 2015

Reprint

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

Pat Sullivan, Sr. VP, SCS Engineers
Pat Sullivan, Senior Vice President, SCS Engineers

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 

Posted by Diane Samuels at 6:00 am

October 14, 2015

NWRA-logoToday, the National Waste & Recycling Association hosted a webinar concerning the revised NSPS (New Source Performance Standards for Landfills) Rule. EPA is revising the NSPS rules which will be tentatively published in the Fall, 2015. These rule changes may impact the way air emissions from landfills are being managed and is a significant change from 1996 published standards. During this informative session, attendees learned:

  • The specific changes the EPA is revising on NSPS and the impact on air emissions;
  • Tactics for landfill owners/operators to minimize the impact;
  • A better understanding of what the EPA constitutes as landfill gas.

If you missed this presentation, NWRA has granted SCS permission to post the slide show on our website. We welcome everyone to view the slide show and thank the NWRA for sponsoring the webinar. Webinar presenters include:

  • Pat Sullivan, Senior Vice President, and SCS National Expert – Landfill Clean Air Act; NSPS.
  • Niki Wuestenberg, Corporate Air Compliance Manager, Republic Services
  • Amy Banister, Senior Director of Air Quality, Waste Management

For more information and answers to your questions please contact Pat Sullivan, SCS Engineers or the webinar presenters.

Click for information about NSPS/NESHAP Compliance Services.

 

Posted by Diane Samuels at 4:19 pm

August 30, 2015

Sign-Alert-iconThe Technical Bulletin is a synopsis of the NSPS rule supplement and the draft EG rule intended by the EPA to strengthen the previously published rule on July 17, 2014, and earlier proposals. The rules frame the requirements and responsibilities created for Municipal Solid Waste Landfills and the Waste and Recycling Industry.

The EPA has provided a 60-day time period from the publication date of August 27, 2015, for industry responses to the draft rules. Responding is critical to properly frame EPA’s rulemaking process; the EPA may add provisions to the final version of the rule based on information received during the comment period.

The Solid Waste Association of North America (SWANA) and the National Waste and Recycling Association (NW&RA) are reviewing the NSPS and EG rule in detail and will be commenting within the prescribed 60-day window.

This SCS Engineers Technical Bulletin, providing a more detailed summary of the rules, is available on the SCS website by clicking here. Share the link or this blog to help speed the efforts to gather information for the Waste and Recycling Industry response.

Contact Pat Sullivan, SCS Engineers, Senior Vice President to request additional information.

Pat Sullivan, REPA, CPP
National Expert – Landfill Clean Air Act; NSPS
SCS Engineers, Senior Vice President

(916) 361-1297

Posted by Diane Samuels at 10:11 pm