A Facility’s Perspective into a Modeled PSD Increment Violation
Midwest Environmental Compliance Conference – MECC 2019
In 2005, dispersion modeling was conducted in Nebraska Bluff Road Landfill as part of the construction permitting process for the Lincoln Electric System Salt Valley Generating Station. The modeling results identified a Prevention of Significant Deterioration (PSD) increment violation at the Bluff Road Landfill resulting from activities associated with landfill operations. The model results predicted an increment violation for particulate matter less than 10 microns (PM10) at the landfill boundary, specifically for the short term 24-hour standard for PM10.
This SCS Engineers’ presentation by Tia Jeter, focuses on the experience of Bluff Road Landfill and the City of Lincoln, as the entities responded to the modeled violation, and provides highlights of the process required to ultimately resolve the increment violation and bring the facility into modeled compliance with the increment.
Resolving the modeled increment violation required coordination with multiple entities, including the local air permitting authority, the Lincoln Lancaster County Health Department (LLCHD), the Nebraska Department of Environmental Quality (NDEQ) and US EPA Region 7. To resolve the violation, facility emission processes, operational limitations, emission controls, model setup, and the compliance boundary was evaluated and revised numerous times. Initial modeling efforts conducted as part of the response utilized the Industrial Source Complex 3 Short Term (ISC3ST) model, which was the EPA-approved dispersion model at the outset of the project. Due to the prolonged timeline of the project, the final compliance modeling scenario submitted to the regulatory agency was completed using AERMOD which is now the EPA-approved dispersion model.
Along the path to compliance there were multiple challenges, including negotiations on emission point modeling methods, clarification on the definition of ambient air as it relates to leased property, the requirement to create federally enforceable compliance requirements, the slow response and feedback from the regulatory authority (ies), and the bureaucratic “hold-up” of other facility projects until resolution of the violation was attained.
Tia’s presentation will provide an overview of the road to compliance for the Bluff Road Landfill from the beginning of the project to the resolution of the increment violation. Her presentation provides an insight into what other facilities may experience in the future as compliance with the National Ambient Air Quality Standards and PSD increment for PM10 and particulate matter less than 2.5 microns (PM2.5) becomes increasingly more scrutinized.
The American Academy of Environmental Engineers and Scientists (AAEES) recently nominated and confirmed Robert Gardner as the Solid Waste Association of North America (SWANA), Trustee to the Board. His term began January 1, 2019, and extends until December 31, 2021.
Mr. Gardner is a Senior Vice President of SCS Engineers and leads SCS’s solid waste management practice, including landfill engineering, landfill gas management, solid waste studies, landfill environmental systems, liquids management, operation and maintenance, and construction.
Mr. Gardner is also SCS’s National Expert on Solid Waste Collection and Routing, supporting municipalities and businesses nationwide to continue or expand their sustainable recycling-reuse programs despite international export restrictions and market fluctuation.
AAEES, a not-for-profit organization serves to protect public health and the environment by recognizing leadership and excellence through accredited Board Certification of Environmental Engineers and Scientists and with professional development opportunities. Mr. Gardner’s expertise supports multiple programs in the solid waste management industry, which have a profound positive impact on the environment, climate change, and human health.
Mr. Gardner is a Professional Engineer in thirteen states and Puerto Rico. He is an AAEES Board Certified Environmental Engineer (BCEE) in Solid Waste Management. In addition to serving the AAEES, Gardner is an active member of the American Society of Civil Engineers, Solid Waste Association of North America, National Society of Professional Engineers, National Waste and Recycling Association, and the Environmental Education and Research Foundation.
The City of Olathe, Kansas is the fastest growing municipality in the Kansas City metro area, and the Solid Waste Division Manager recognized that increasing population; new, single and multi-family home developments; and growth in commercial establishments would require additional services, resources, and infrastructure to continue the same excellent level of service. The City determined that a long-term, solid waste management plan (Plan) was necessary to address future waste management needs of the City, as well as optimize the performance and efficiency of existing waste management services and facilities.
Olathe’s long-term solid waste plan was a first for the City and resulted in creating tangible pathways to environmental and financial sustainability for the next several decades despite the cost of recycling programs. Customers and elected officials support the City’s approach, surpassing another sometimes-prickly hurdle.
In their recent APWA Reporter article, Karen Luken and Anastasia Welch of SCS Engineers describe how the Olathe Solid Waste Division now has a strategic approach and schedule for adding collection routes, increasing recycling, purchasing equipment, and expanding facilities.
This informative article, Strategic planning for sustainable and stakeholder-supported waste systems is available online at APWA.
Solid Waste Management Planning
Speakers include Andrew Wheeler, Administrator, U.S. Environmental Protection Agency discussing regulatory policy about the environment, energy, and resources. SCS a proud sponsor looks forward to seeing you there!
A few of the topics of this year’s conference will include water law, brownfields, public service, fracking, enforcement, grid resiliency, PFAS, mineral exploration, and more, even the environmental implications of the new cannabis industry.
Dan Sola, a Hydrogeologist and Project Director at SCS Engineers, chats with attorney Shell Bleiweiss on expert witness testimony. In a rare article, Mr. Sola, an expert witness for environmental issues, tells his story of what it took to become a successful and sought after witness, while Mr. Bleiweiss answers from the attorney’s perspective.
… That’s expert testimony, and that’s why I love it. Everything you have ever said or written is on the line. It is a battle of intellect and wits. The rules of the game are hundreds of years old and amount to a philosophical discourse on the nature of truth. It is a language where everyday meanings overlap with esoteric jargon. It is a highly civilized conversation among oath-bound professionals wanting nothing more than for the other to fail. – Dan Sola. EWRG 2019 article.
Daniel Sola, PG of SCS EngineersSola’s areas of expertise include soil and groundwater cleanup, hydrogeological evaluation, computer modeling, hazardous waste regulations, human and ecological risk assessment, expert witness and public testimony, and environmental review.
If your facility is subject to Process Safety Management and Risk Management Plan regulations, or even if you are a mom and pop grocery store, during the life of your business you’ll experience organizational change. William Lape, of SCS Engineers, writes about how we need to consider the impacts on a facility’s PSM/RMP or ARM programs and on the operation of the ammonia refrigeration system itself.
Published in the RETA Breeze, Managing Organizational Change, How It Impacts Your Ammonia Refrigeration System
A well-sited transfer station could possibly save millions a year in operation costs, but it’s nearly impossible to find a location with every desirable checklist item. Project developers and one municipality share which priorities tend to matter the most and how to satisfy as many as possible, whether it is accessibility, traffic considerations, zoning, among others.
“There has been an uptick in construction of transfer stations in the past several years. Governments want to have facilities in their community for convenience,” says Michael Kalish, vice president of SCS Engineers.
Easy access is key.
“Haulers want to collect material quickly and easily to get rid of it and get back on the road. Otherwise, it costs a lot of money and time,” says Kalish.
Read the article How to Resourcefully Site a Transfer Station.
Learn how four municipalities are finding ways to lower their operational costs to balance the rising cost of recycling.
Three distinguished recycling experts describe how cities from Kirkland, Washington to Oklahoma City to Virginia Beach and Chesapeake have taken action to lower their operational costs, offsetting the cost of recycling. Each city takes a different approach, but all are using sound strategies to balance the books successfully and sustainably.
APWA Click-Listen-Learn event details and registration – March 14
11:00 am Eastern | 10:00 am Central | 9:00 am Mountain | 8:00 am Pacific
Participants will learn:
Participants may earn CEU credit for attending during the Test Your Knowledge portion of the program evaluation.
APWA encourages group participation and follows up as part of their program to Continue the Conversation promoting a deeper understanding of how these solutions relate directly to your responsibilities, agency or department, and city.
Free to all APWA Members | Fee for others is $99
Stormwater management at landfills is changing as owners/operators are adapting their operating plans and designs to minimize the risks that come with heavier rainfall, and severe storm conditions. Landfill engineers are “overdesigning,” in regions hard hit in recent years by severe weather, and not designing for what is labeled as a statistically probable 25-year-storm.
Operations and maintenance are also preparing for changing conditions. William Mojica, Republic Services Director of Environmental Compliance is quoted in this article saying “It’s understanding the facility’s lifecycle, what best management practices (BMPs) are required and anticipating what may come.”
Jonathan Meronek, of SCS Engineers, notes similar strategies are being explored or employed along the U.S. coastlines including designing retention facilities to handle much larger storms.
With the number of LFG monitoring technologies out there, it can be difficult for operators to distinguish which is the best fit. The authors, Pat Sullivan and John Henkelman of Understanding Landfill Gas Monitoring Techniques, do just that, help readers find the approach that works best for their landfill monitoring needs.
Methane can be monitored above the surface of the landfill as a gauge of potential emissions or can be directly measured using techniques that test for the rate or flux of emissions. The above-surface monitoring techniques for gauging potential emissions include surface emission monitoring, ground-based or low-altitude imaging and satellite and aerial imaging.
Landfill methane measurement is the direct measurement of methane emissions from landfills. Direct measurement of methane is more expensive than surface emission monitoring. Four ways to measure landfill methane directly are flux chamber testing, plume measurement, micrometeorological methods, and dispersion modeling.
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