1. Implementation of Final NSPS XXX Rule How to Survive the 1st Year
The Standards of Performance for Municipal Solid Waste Landfills (NSPS Subpart XXX) was published final on August 29, 2016 and became effective on October 28, 2016.  For sites that must comply with this rule, the path toward compliance with this new rules is somewhat confusing and has many small pieces that need to be addressed in order to comply with the new rule. 
This presentation will look at the notifications, recordkeeping, and reporting requirements in NSPS XXX and will inform landfill owners and operators understand what needs to be done to be in compliance with the rule during the first year
October 2016

2. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
In this presentation we will briefly look at the EPA’s rulemaking history for landfills, the applicability of the new NSPS/EG rules, how NESHAP AAAA still requires compliance with the old rules, the outline of the NSPS XXX rule that includes citations, the first actions sites should take to comply with NSPS XXX, the biggest changes in the new rules and the impacts on industry, and then I will summarize the first actions for landfills to take to comply at the end.
This presentation won’t include every change in the rules since there are so many, but it will include the approach we recommend to comply, which is an approach that is consistent with industry leaders.
We are going to start with a brief history of the rulemaking so that we understand how we got to this point in the process.
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3. Rulemaking History
EPA began regulating landfills (WWW & Cc) that accepted waste on or after November 8, 1987
July 17, 2014 – Subpart XXX was proposed for new landfills & advanced rulemaking notice for existing landfills
August 27, 2015 – Subpart Cf was proposed for existing landfills; supplemental changes proposed for XXX
August 29, 2016 – Final XXX and Cf rules were published
October 28, 2016 – Effective date for final rules
U.S. EPA began regulating landfills in 1996 when they published air emissions standards for Municipal Solid Waste (MSW) Landfills under section 111 of the Clean Air Act. The rules were NSPS Subpart WWW that applied to new landfills and the NSPS Subpart Cc know as the EG that applied to existing landfills. With these rules landfills began regulating landfills as old as November 8, 1987.
EPA is required to review the NSPS standards every 8 years. As a result of their review of the first landfill regulations (they are a little behind), EPA determined that the rules were insufficient to protect public health and the environment and needed to be revised.
On July 17, 2014 EPA published a new proposed NSPS rule- designated as Subpart XXX- under the authority of Section 111 of the CAA and also issued an advanced notice of proposed rulemaking to inform interested parties that they plan to revise the EG for existing landfills- later designated as Subpart Cf- under the authority of Section 111(d) of the Act.
Implementation Schedule
• The final rules were both published on 8/29/16, and are both effective 10/28/16.
• However, EG (Subpart Cf): EG rules are implemented by the states/local agencies, not EPA. These agencies will have until May 30, 2017 to prepare their EG rules under a State Plan. U.S. EPA will then have 4 months to either approve or reject the State Plan. Note that these State Plans can be more strict than what EPA finalizes under Subpart Cf. States can also choose to not prepare a SIP, in which case a Federal Plan (which has yet to be developed by U.S. EPA) will apply to landfills in that state.
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4. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
Now we are going to take a look at the applicability of NSPS XXX.
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5. Applicability of NSPS XXX Rule
Applies to MSW LFs that commenced construction, reconstruction, or modification after July 17, What is a modification? Defined as an  in the permitted volume design capacity by either lateral or vertical expansion based on its permitted design capacity as of July 17, 2014.
Industry Approach: Follow “shovel in the ground” approach for commencing construction. We interpret shovel in the ground as being first action that is uniquely done to construct the expansion area (horizontal = base grades; vertical expansion = any construction work to prepare area to go higher such as soil berms)
Modification does not occur until the owner or operator commences construction on the lateral or vertical expansion.
State agencies may have different interpretation (call on any regulators in the audience to get their perspective)
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6. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
Next we are going to discuss one of the hiccups we have already found in the implementation of the new rule – the current NESHAP AAAA refernces compliance with NSPS WWW.
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7. Legacy NSPS WWW Reference in NESHAP AAAA
Lists requirements for SSM events and requires compliance with NSPS WWW or NSPS Cc (EG)
Overlapping applicability of old and new NSPS/EG rules is threshold issue that contravenes the CAA
NESHAP AAAA needs to be revised to require compliance with new rules
It will probably be a few years before EPA revises NESHAP AAAA. Industry groups filed petitions week of 10/24 to compel rule changes; sites must not be burdened with having to comply with 2 rules- submit duplicate reports under 2 different rules, etc. Industry asserts that Subpart XXX and CF are more stringent than WWW/Cc and therefore sufficient to demonstrate compliance with NESHAPs AAAA.
Further states do not have legal authority to revise applicability provisions of the NSPS or NESHAPs standards.
In the interim, continue to comply with WWW and follow the compliance schedule in XXX until further notice.
For now, comply with NSPS WWW and XXX
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8. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
Ok, we understand how we got here and who the rule applies to – let’s take a look at how the rule is laid out…
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9. 40 CFR 60 Subpart XXX
§ Applicability Designation of affected source Delegation of authority § Definitions § Standards for air emissions § Operational standards for GCCS § Test methods & procedures
It is organized similar to NSPS WWW.
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10. 40 CFR 60 Subpart XXX (cont.) § 60.765 Compliance procedures
§ Monitoring of operations
§ Reporting requirements
§ Recordkeeping requirements
§ Specifications for active CS
Be aware that requirements are not always found where they should be. For example, the requirement to record GPS coordinates for surface emissions monitoring is found in the reporting section and not the monitoring section.
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11. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
We are going to turn our focus now to what a facility needs to do first to comply with the new rules…
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12. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
There are several steps that a XXX site needs to take in the next few months to comply with NSPS XXX. We are going to first look at the design capacity report.
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13. Initial Design Capacity Report
Submit:
By Nov 28, 2016 for LFs that were constructed, reconstructed, or modified Jul 17, Aug 29,
Within 90 days for affected LFs after date of commenced construction
Initial Reporting Industry Approach: XXX sites submit initial design capacity reports, NMOC reports.
{NOTE: This is approach both WM and Republic are taking} Also submit for sites that received permits prior to 2014 but commenced construction after the July 17, 2014 date since modification is based on when construction commenced on the most recent permitted expansion that increased the design capacity of the landfill.
You can combine the initial design capacity and Tier 1 NMOC reporting into one report. Send to both the state/local agency and the respective Region office.
If you have valid Tier 2 results that show under 34 Mg/yr then submit with the initial design capacity and NMOC 1 report. If have results between 34 and 50 Mg/yr then…..can redo testing within 180 days to see if below 34 Mg/yr or submit initial design plan within 12 months.
For sites that were over 50 Mg/yr under WWW and operate GCCS per NSPS, In the design capacity and NMOC reports, reference you will submit updates to Design Plan within 12 months.
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14. Amended Design Capacity Report
Submit:
Within 90 days of an  in the max design capacity from below 2.5 mil m3/Mg to above 2.5 mil m3/Mg
(May result from  in the permitted volume of the LF or an  in the density)
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15. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
The next piece, which we already touched on in the design capacity report discussion is the NMOC emission rate report.
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16. NMOC Emission Rate Report
Submit:
By Nov 28, 2016 for LFs that were constructed, reconstructed, or modified Jul 17, Aug 29,
Within 90 days for affected LFs after date of commenced construction
Initial Reporting Industry Approach: XXX sites submit initial design capacity reports, NMOC reports.
You can combine the initial design capacity and Tier 1 NMOC reporting into one report. Send to both the state/local agency and the respective Region office.
If you have valid Tier 2 results that show under 34 Mg/yr then submit with the initial design capacity and NMOC 1 report. If have results between 34 and 50 Mg/yr then…..can redo testing within 180 days to see if below 34 Mg/yr or submit initial design plan within 12 months.
For sites that were over 50 Mg/yr under WWW and operate GCCS per NSPS, In the design capacity and NMOC reports, reference you will submit updates to Design Plan within 12 months.
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17. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
The next item we will look at to comply with NSPS XXX is the GCCS design plan.
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18. Thresholds for GCCS Design capacity ≥ 2.5 MM Mg & 2.5 MM m3
NMOC emission ≥ 34 Mg/yr
If NMOC ≥ 34, install/startup system < 30 mo
Before we get into the notification requirements, I wanted to take a minute to address the changes in the thresholds for installation of a GCCS under NSPS XXX.
The new rules only apply to landfills that have triggered the design capacity threshold of 2.5 million megagrams (mass) and 2.5 million cubic meters (volume)
Impact of changes
Active landfills will now trigger GCCS requirements earlier
Landfills with lower waste acceptance volumes could now trigger NSPS requirements
Additional maintenance on GCCS components in the active working areas of the landfill
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19. GCCS Design Plan Within 1 yr NMOC emission rate report ≥ 34 Mg/yr
PE prepare and approve (PE stamped)
Administrator has 90 days to decide to accept PE Stamp or submit design plan for agency review/approval
If review is required, plan will be
Approved
Rejected
Additional information will be requested
No review  implement the plan at own risk
Design Plan Industry Approach: follow initial XXX timeline and submit the initial Design Plan. Keep the WWW approved plans intact; submit initial XXX GCCS plan and additional updates to the WWW approved plan with PE page and state in cover letter we continue to follow the WWW approved plan for XXX compliance/incorporate approved WWW plan by reference in XXX updates and state we will comply within 30-month timeline for XXX updates. Current WWW plan applies and continue to follow WWW until we receive agency approval and also while we upgrade GCCS and other monitoring requirements to meet XXX. Any new XXX requirements, must state that these are prospective (ability to isolate, treatment plan,
Going forward, the GCCS design plan must be revised within 90 days of expanding operations to an area not covered by the previously approved design plan and/or before installing/expanding the GCCS in a manner inconsistent with the previous design plan
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20. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
NSPS XXX sites who have on-site LFG treatment will also need to meet the new requirement of having a site–specific treatment monitoring plan
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21. Site-Specific Treatment Monitoring Plan
Sites w/ LFG treatment system must develop site-specific treatment monitoring plan to assure proper operation
Submit as part of GCCS Design Plan
The plan (and records) be complete when the initial CCS design plan is submitted
Sites with LFG treatment system must develop site-specific treatment monitoring plan to ensure the treatment system is operating properly
Treatment Monitoring Plan:
EPA intended this would be a stand-alone plan; however per the rule language, the treatment monitoring plan is part of the GCCS Design Plan (response to comments support this). Although the Preamble mentions submitting the treatment monitoring plan with a Title V application, the rule requirements for the Design Plan include the treatment monitoring plan. Although the preamble language conflicts with rule language, the rule language supercedes the Preamble language.
The treatment monitoring plans should document current monitoring practices – identify acceptable operating ranges, frequency of monitoring and who is responsible for collecting data. If third party developer owns treatment system, work with owner/operator to develop and implement the plan – could follow SSM plan process.
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22. Site-Specific Treatment Monitoring Plan (cont.)
Responsible party (job title) for data collection
Records
Filtration
De-watering
Compression parameters
Monitoring methods, frequencies, & operating ranges for each monitored operating parameter (based on manufacturer’s recommendations)
Documentation of item 6 along with justification of use
Processes & methods used to collect the necessary data
Description of the procedures & methods used for QA, maintenance, & repair of all continuous monitoring systems
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23. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
Because NSPS XXX is a new rule, sites will have to comply with the initial performance test requirements under the rule, even if they have already met the requirements for initial performance testing under NSPS WWW.
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24. Initial Performance Test
Submit test report within 180 days after the initial startup of the approved control system
Performance test to be completed using test methods specified in section (d) for enclosed flares and (e) for open flares.
Industry approach: For flares that were already in place, perform a test, even if tested before, and submit an initial performance test report within 180 days. You may be able to use an old test if less than 5 years old for the initial performance test, but would have to submit a request to EPA and be granted approval to use an old test.
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25. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
As with any new rulemaking, facility operating permits will need to be updated to reference the new rule. Keep in mind, any rule that applies to operations at a facility applies whether it is referenced in the facility operating permit or not.
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26. Operating Permit Part 70, Part 71
For sites that do not have an existing Title V Operating Permit, then submit:
By Nov 28, 2016 for LFs that were constructed, reconstructed, or modified Jul 17, Aug 29,
Within 90 days for affected LFs after date of commenced construction
Title V updates: Follow current Title V update process. When time comes, then reference XXX requirements – try to not pull in full language just the citations. Subpart AAAA remains.
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27. Operating Permit Part 70, Part 71
For sites having an existing Title V permit, submit modification according to Title V rule requirements. Typically:
> 3 yr of permit term remain: address in renewal application
< 3 yr of permit term remain: reopen to add new requirements
Work with your air permitting agency
Title V updates: Follow current Title V update process. When time comes, then reference XXX requirements – try to not pull in full language just the citations. Subpart AAAA remains.
{You can ask any agency representatives how they expect this to be handled in their state. While they will likely need to add the requirements to the permits sometime, I doubt that it will be a high priority if this is the only update that needs to be made to the permit}
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28. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
Another new requirement under NSPS XXX is the reporting of liquids additions at a landfill (better known as leachate recirculation)
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29. Liquids Addition Recordkeeping
Volume of leachate recirculated (gal/yr) & the reported basis for those estimates (records or engineering estimates)
Total volume of all other liquids added (gal/yr) & the reported basis for those estimates (records or engineering estimates)
Surface Area (acres) over which the leachate is recirculated or otherwise applied
Surface area (acres) over which any other liquids are applied
Total waste disposed (Mg) in the areas with recirculated leachate/added liquids based on on-site records or engineering estimates
Landfills that have employed leachate recirculation or added liquids based on RDD permit within the past 10 years must submit to the Administrator, annually:
Volume of leachate recirculated (gal/yr) and the reported basis for those estimates (records or engineering estimates)
Total volume of all other liquids added (gal/yr) and the reported basis for those estimates (records or engineering estimates)
Surface Area (acres) over which the leachate is recirculated or otherwise applied
Surface area (acres) over which any other liquids are applied
Total waste disposed (Mg) in the areas with recirculated leachate/added liquids based on on-site records or engineering estimates
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30. Liquids Addition Reporting
Initial report must contain the recordkeeping information for the initial year as well as previous 10 yrs, to the extent historical data are available in on-site records
For LFs that commenced construction, reconstruction, or modification between Jul 17, 2014 and Aug 29, 2016, initial report containing data for the first 12 months after Aug 29, 2016 (Sep Aug 2017) must be submitted no later than Sep 27, 2017
For LFs that commence construction, reconstruction, or modification for landfills after Aug 29, 2016, initial report is due 13 months after construction commenced containing data for the first 12 months
Subsequent annual reports must be submitted no later than days after the previous report was submitted
Only 30 sites ever received RD&D permits. All the information to be collected is not available and what is available is not in format required by the rules, not for non RD&D permits and not for other sites. This is beyond what sites already collect. We can provide volume but we do not have other records and not in the format required by the rules so most if not all site will not have historical records.
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31. Initial Actions to Comply with NSPS XXX
Design Capacity Report
NMOC Emission Rate Report
GCCS Design Plan
Site-Specific Treatment Monitoring Plan
Initial Performance Test
Permit Updates to Include NSPS XXX
Liquids Addition Reporting
Electronic Reporting
The last compliance action we are going to discuss today is electronic reporting. This is not just electronic submittal of compliance reports to the state agencies, this is a new requirement we have not had before.
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32. Electronic Reporting Submit electronic copies of:
Certain required performance test reports
NMOC emission rate reports
NSPS Annual reports
Tier 4 emission rate reports
Liquids Addition reports
Must submit results of each performance test within 60 days after the date of completing each performance test (as defined in Section 60.8).
Initially – the reporting tool only support stack test method 25A. The tool currently does not support other NMOC stack testing, NMOC test reports, Tier 4. test reports, liquids reporting or annual NSPS reporting. Continue to submit reports as you currently do to the state and region offices, as applicable. Continue to monitor the electronic reporting system to see if and when it supports other reporting.
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33. Electronic Reporting (cont.)
EPA’s Central Data Exchange (CDX) using the Compliance & Emissions Data Reporting Interface (CEDRI)
ERT Users Manual: rs%20Guide% %20Release.pdf
CEDRI Users Manual:
ERT Training Website:
Must submit results of each performance test within 60 days after the date of completing each performance test (as defined in Section 60.8)
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34. Electronic Reporting (cont.)
Electronic reports only apply to those performance tests conducted using test methods that are supported by the Electronic Reporting Tool (ERT)
A list of the pollutants and test methods supported by the ERT is available at:
When the EPA adds new methods to the ERT, a notice will be sent out through the Clearinghouse for Inventories and Emissions Factors (CHIEF) Listserv: emissions-inventories/emissions-inventory-listservs
Sites are encouraged to check the ERT website regularly for up-to-date information on methods supported by the ERT
Once new form has been available in CEDRI for 90 days, must begin submitting all subsequent reports via CEDRI
Some of the test methods landfills often use for flare testing are included. Methods 1 through 4 are included, so 3C is included. Method 25 and 25C are NOT, but method 25 A is included.
For pollutants, methane only appears to be included as part of total organic compounds.
Initially – the reporting tool only support stack test method 25A. The tool currently does not support other NMOC stack testing, NMOC test reports, Tier 4. test reports, liquids reporting or annual NSPS reporting. Continue to submit reports as you currently do to the state and region offices, as applicable. Continue to monitor the electronic reporting system to see if and when it supports other reporting.
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35. Electronic Reporting - CEDRI Roles
Preparer - prepares reports for signature, assembles submission packages.
Cannot sign or submit.
Only role a consultant can have
Certifier - responsible official or duly authorized representative that is authorized to sign reports for the facility.
Signs and submits reports to CEDRI & can perform preparer functions
Delegated Certifier - delegated by the Certifier to act on their behalf
Can perform same actions as certifier
The 3 roles on this slide are the only roles to choose from for non-regulators.
There is also a role for state and EPA reviewers so that they can access and review submissions.
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36. Electronic Reporting - Getting Started
1. Go to
2. Responsible official register for CDX
Request access to CEDRI
Request access to your facility
Request the role of “certifier”
3. “Preparers” and “Delegated Certifiers” register for CDX
Request access to desired facilities for approval by “certifier”
Request the role of “preparer” or “delegated certifier”
You should register for CDX a few weeks before your first reporting deadline. When you register for CEDRI you will be prompted to select the program service that you desire and that is where you will choose CEDRI. The Certifier will have to provide proof that they are the responsible official so their registration is more involved and takes longer to do and for EPA to approve.
If you run into problems, there are user guides and videos online and you can also questions to EPA.
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37. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
Now that we have seen what sites need to do initially from a compliance perspective, let’s now look at how the rule changes impact the everyday operations at a landfill that is subject to NSPS XXX.
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38. Rule Changes and Industry Impacts
Wellfield Monitoring
Surface Emissions Monitoring
NMOC Emission Demonstrations
Startup, Shutdown, Malfunction
If you were hear last year, we discussed what changes we expected in the XXX rules. Now we are going to dig into what was is in the final rules.
It is important to emphasize that until the site receives an approved design plan under XXX, the site should not proceed with Subpart XXX monitoring, recordkeeping and reporting but continue to follow WWW MRR practices.
Under XXX, the site has 12 months to submit the design plan from date of the NMOC report that shows NMOC exceeds 34 Mg/yr and 30 months from date of the NMOC report that shows NMOC exceeds 34 Mg/yr to install/upgrade the GCCS before monitoring must start.
Need to work with state agencies on approval process (accept the PE certification in writing or agency review/approve in writing) – do not want to operate “at risk” absent an approved plan.
Now we are going to take a look at the changes in wellfield monitoring under NSPS XXX.
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39. Wellfield Operations P < 0 at each wellhead, monitor every month
T < 131 F at each wellhead, monitor every month
Monitor N2 or O2 concentration every month
Still applies to waste in place 5 years for active landfills and 2 years for closed/final grade landfills
Can still operate well under positive pressure if elevated temperature or suspected fire
Can request HOV
Must keep records of monthly monitoring for pressure, temperature, and nitrogen/oxygen
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40. Pressure or Temperature Exceedance
If P≥0 or T≥131F initiate corrective action within 5 cal days
>15 calendar days: If exceedance, must conduct “root cause analysis” & correct as soon as practicable, but not later than 60 days after initial exceedance
>60 days: If compliance cannot be achieved, conduct a “corrective action analysis” & develop an implementation schedule to achieve compliance as soon as practicable, but not > 120 days following the initial exceedance
>120 days: If compliance cannot be achieved, submit the root cause analysis, corrective action analysis, and corresponding implementation timeline to the Administrator
If positive pressure exists, action must be initiated to correct the exceedance within 5 calendar days. Any attempted corrective measure must not cause exceedances of other operational or performance standards.
If negative pressure cannot be achieved within 15 calendar days of first exceedance, must conduct root cause analysis and correct exceedance as soon as practicable, but no later than 60 days after positive pressure was first measured.
If corrective actions cannot be fully implemented within 60 days, must also conduct a corrective action analysis and develop an implementation schedule to complete the corrective action(s) as soon as practicable, but no more than 120 days following the positive pressure measurement. A notification must also be submitted to the Administrator within 75 days of the initial exceedance and additional information must be submitted with the next annual report.
If corrective action is expected to take longer than 120 days to complete after the initial exceedance, must submit the root cause analysis, corrective action analysis, and corresponding implementation timeline to the Administrator within 75 days of the initial exceedance for approval.
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41. Root Cause Analysis
An assessment conducted through a process of investigation to determine the primary cause, and any other contributing causes, of positive pressure at a wellhead
An assessment conducted through a process of investigation to determine the primary cause, and any other contributing causes, of positive pressure at a wellhead.
This is how a root cause analysis is defined in Subpart XXX, but we will see in the next slides that it applies to both positive pressure and elevated temperatures at wellheads.
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42. Corrective Action Analysis
A description of all reasonable interim and long-term measures, if any, that are available, and an explanation of why the selected corrective action(s) is/are the best alternative(s), including, but not limited to, considerations of cost effectiveness, technical feasibility, safety, and secondary impacts
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43. O2 & N2 Monitoring Wellhead
1x/month: monitor O2 or N2 concentration
Document any N2 level ≥ 20%
Document any O2 level ≥ 5%
O2 & N2 exceedances do not need to be corrected in XXX, however AAAA refers to WWW so LFs do need to correct until such time that AAAA is updated
Must monitor nitrogen or oxygen concentration in the LFG on a monthly basis
Must keep records of any wellhead nitrogen level at or above 20% and any wellhead oxygen level at or above 5% so that the GCSS can be adjusted accordingly
No corrective actions for exceedances
Nitrogen level must be determined using Method 3C.
Oxygen level must be determined by an oxygen meter using Method 3A, 3C, or ASTM D
Portable Gas Analyzer may be used provided that it is calibrated & meets all QA/QC requirements according to Method 3A
ASTM D may be used as an alternative to Method 3A for wellhead monitoring as long as all the quality assurance is conducted as required by ASTM D (sample location before combustion)
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44. Rule Changes and Industry Impacts
Wellfield Monitoring
Surface Emissions Monitoring
NMOC Emission Demonstrations
Startup, Shutdown, Malfunction
We are now going to look at the changes to the quarterly surface emissions monitoring under NSPS XXX
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45. Surface Emissions Monitoring
Monitor CH4 emissions every calendar quarter
Monitor the perimeter of the collection area & along a pattern that traverses the LF at no more than 30-m intervals
Monitor where visual observations indicate elevated concentrations of LFG
distressed vegetation
cracks or seeps in the cover
all cover penetrations
Must conduct surface testing around the perimeter of the collection area and along a pattern that traverses the landfill at no more than 30-meter intervals and where visual observations indicate elevated concentrations of LFG, such as distressed vegetation and cracks or seeps in the cover and all cover penetrations. Note that (d) says "at no more than 30 meter intervals "however (c)(1) says "at 30 meter intervals"
According to the supporting documentation for Subpart XXX, cover penetrations include wellheads but do not include items such as survey stakes, fencing or litter fencing, flags, signs, trees, and utility poles. EPA also confirmed more broadly in its response to comments that “cover penetrations” is only intended to include “component[s] of the GCCS system or leachate collection and control system that completely passes through the landfill cover into waste, such as wellheads, leachate risers, and manholes.” Response to Comments Document at 745.
Thus you must monitor any openings that are within an area of the landfill where waste has been placed and a gas collection system is required. Areas with steep slopes or other dangerous areas may be excluded from the surface testing.
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46. Surface Emissions Monitoring (cont.)
This slide shows an example of the serpentine pattern under the old NSPS XXX and we have added all of the LFG monitoring wells in blue which are included in the “all cover penetrations” language in the final rule.

47. Surface Emissions Monitoring (cont.)
Report each location of CH4 ≥ 500 ppm
Determine the coordinates (Lat/Lon) using an instrument with an accuracy ≥ 4 m
Coordinates must be in decimal degrees ≥ 5 decimals
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48. Rule Changes and Industry Impacts
Wellfield Monitoring
Surface Emissions Monitoring
NMOC Emission Demonstrations
Startup, Shutdown, Malfunction
NSPS XXX offers something new and exciting in the NMOC emission demonstrations – lets see what that is all about
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49. NMOC Emissions Demonstration Tiers
Tier 1 – mass-based emission rate
Tier 2 – site-specific NMOC emission concentration
Tier 3 – site-specific methane generation rate constant
Tier 4 – surface methane emissions demonstration
New in Subpart XXX
Onerous!
We are going to talk about the ins and outs of Tier 4 in the next 10 slides, so that gives you some idea of how onerous it really is…
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50. Tier 4 Demonstration Optional surface CH4 emissions demonstration
Must be conducted every calendar quarter
Allowed only if LF can show NMOC ≥ 34 < 50 Mg/yr
Not allowed if both Tier 1 & Tier 2 show NMOC emissions >50 Mg/yr
Can operate voluntary CCS during Tier 4 demonstration (with some restrictions)
A site with a voluntary GCCS can operate the GCCS during Tier 4 monitoring provided that the GCCS has operated 6,570 out of 8,760 hours preceding the Tier 4 demonstration and during the Tier 4 monitoring the GCCS must operate as it normally would to collect as much LFG as possible
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51. Tier 4 Demonstration (cont.)
Same monitoring patterns as “regular” surface emissions monitoring
Approved instruments:
organic vapor analyzer
flame ionization detector (FID)
other portable monitor meeting the specifications
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52. Tier 4 Demonstration Notifications
Must notify planned date(s) for Tier 4 demonstration
must provide a description of the wind barrier
notification postmarked at least 30 days before scheduled date
If scheduled date is delayed due to weather conditions not meeting the wind requirements, notify Administrator ( /phone) no later than 48 hr before any delay or cancellation
Plan a new test date
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53. Tier 4 Demonstration Restrictions
Determine “background” concentration  move the probe inlet upwind and downwind ≥ 30 m from the waste mass boundary of the LF
Follow EPA Method 21 (Appx A, Section 8.3.1) except that probe inlet must be placed ≤ 5 cm above LF surface
use a mechanical device (e.g., wheel on a pole) to constantly measure the distance above the surface
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54. Tier 4 Demonstration Restrictions (cont.)
Must use a wind barrier (funnel) when onsite wind speed > 4 mph or wind gust > 10 mph
Average on-site wind speed must also be determined in an open area every 5 minutes
Use an anemometer with a continuous recorder & data logger for the entire duration of the monitoring event
Wind barrier must be on the ground (no turbulence)
Tier 4 cannot be conducted if average wind speed exceeds 25 mph
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55. Tier 4 Demonstration Recordkeeping
Must keep calibration records:
date of calibration & initials of operator performing
instrument scale(s) used
describe any corrective action taken if meter readout can’t be adjusted to correspond to calibrations gas value
Digital Photo must be taken of the instrument setup & wind barrier
time & date stamped
take before 1st sampling location & at last sampling location after sampling at end of day
keep records of timestamp of each surface scan reading
should be detailed to the nearest second based on when the sample collection begins
log for the length of time each sample was taken using a stopwatch (the time the probe was held over the area)
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56. Tier 4 Demonstration Recordkeeping (cont.)
Record location of each surface scan reading
determine coordinates using an instrument with accuracy of at least 4 meters
coordinates must be in decimal degrees with at least 5 decimal places
Record monitored CH4 conc (ppm) of each reading
Record background CH4 conc (ppm) using most recent calibration
For readings taken at each surface penetration, record the unique identification location label
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57. Tier 4 Demonstration Results
Any measured CH4 concentration ≥ 500 ppm
must submit a GCCS design plan within 1 year
must install & operate a GCCS within 30 months
After 4 consecutive quarterly monitoring periods, no exceedances of 500 ppm  continue Tier 4 monitoring
quarterly (open landfills)
annually (closed landfills)
Rule language states must submit design plan within 1 year and install /operate GCCS within 30 months from the date of the most recent NMOC report in which NMOC emission rate equals or exceeds 34 Mg/yr. - could be tricky if site Tier 4’s show no exceedances for multiple quarters. May require site to do annual NMOC reporting to “slide” the Design Plan and GCCS install trigger dates
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58. Tier 4 Demonstration Reporting
Initial Tier 4 report submitted annually, starting within 30 days of completing the 4th quarter event
Tier 4 report must be submitted within 1 year of the first measured exceedance of 500 ppm of CH4
Tier 4 report must also include the results of the most recent Tier 1 & Tier 2 results to verify the LF does not exceed 50 Mg/yr NMOC
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59. Rule Changes and Industry Impacts
Wellfield Monitoring
Surface Emissions Monitoring
NMOC Emission Demonstrations
Startup, Shutdown, Malfunction
Last, but certainly not least, we are going to look at how NSPS XXX impacts startups, shutdowns, and malfunctions at landfills…
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60. Startup, Shutdown, Malfunction (SSM)
XXX applies at all times, including periods of SSM
If the GCCS is not operating, the system must be shut down; all valves that could contribute to venting must be closed within 1 hour of the GCCS not operating
Keep & submit records of all periods when the GCCS doesn’t operate
Monitoring equipment malfunctions
60.766(h) The monitoring requirements of paragraphs (b), (c) (d) and (g) of this section apply at all times the affected source is operating, except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities. A monitoring system malfunction is any sudden, infrequent,
not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused in part by poor maintenance or careless operation are not malfunctions. You are required to complete monitoring system repairs in response to monitoring system malfunctions and to return the monitoring system to operation as expeditiously as practicable.
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61. Presentation Outline Rulemaking History Applicability of NSPS XXX Rule
Legacy NSPS WWW Reference in NESHAP AAAA
XXX Specific Citations
Initial Actions to Comply with NSPS XXX
Rule Changes and Industry Impacts
Summary - First Actions
We are almost through the presentation and we wanted to circle back so that you have a first steps list of what you need to do if your site is subject to NSPS XXX.
© 2016 Cornerstone. All rights reserved.

62. Summary - First Actions
For sites that commenced construction, reconstruction, or modification between July 17, 2014 and August 29, 2016
Action
Deadline
Submit Design Capacity Report
11/28/2016
Submit NMOC Emission Rate Report
Submit GCCS Design Plan
Within 1 yr NMOC Emission Rate Report ≥ 34 Mg/yr
Perform & Submit Report for Initial Performance Test
Within 180 days of required installation date
Complete Site-Specific Treatment Monitoring Plan
By submittal of GCCS Design Plan
Submit Permit Modification to Include NSPS XXX
11/28/16 or as required by agency
Begin Recordkeeping for Leachate Recirculation
8/29/2016
Register for Electronic Reporting
At least a few weeks before 1st report due
Also, the 1st annual leachate report is due by September 27, 2017.
Reminder that e-reporting tool does not yet support NSPS XXX reporting other than for Method 25A stack testing.
© 2016 Cornerstone. All rights reserved.

63. Summary - First Actions (cont.)
For sites that commenced construction, reconstruction, or modification after August 29, 2016
Action
Deadline
Submit Design Capacity Report
Within 90 days of applicability
Submit NMOC Emission Rate Report
Submit GCCS Design Plan
Within 1 yr NMOC Emission Rate Report ≥ 34 Mg/yr
Perform & Submit Report for Initial Performance Test
Within 180 days of required installation date
Complete Site-Specific Treatment Monitoring Plan
By submittal of GCCS Design Plan
Submit Permit Modification to Include NSPS XXX
As required by agency
Begin Recordkeeping for Leachate Recirculation
When rule applicable
Register for Electronic Reporting
At least a few weeks before 1st report due
Also, the first annual leachate report is due 13 months after the rule becomes applicable and must contain data for the first 12 months after the rule becomes applicable.
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64. Cornerstone Environmental Group, LLC
Questions?
Contact Information
Scott D. Miller
Cornerstone Environmental Group, LLC
That wraps up our presentation today. If you have any general questions about the implementation of NSPS XXX, I would be happy to try and answer your questions now. If you have specific questions about your particular site, please feel free to catch up with me or any of the Cornerstone air personnel in attendance and we can hopefully provide you with some answers.
Thanks again for coming today.
© 2016 Cornerstone. All rights reserved.