1. New Source Performance Standards XXX Rule Surviving 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
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January 31, 2017

2. Presentation Outline Applicability of NSPS XXX Rule
Legacy NSPS WWW Ref in NESHAP AAAA
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. Rules Published and Effective Date
2016
August 29
Final XXX & Cf Rules Published
October 28
Rules in Effect
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. Applicability of NSPS XXX Rule
Applies to MSW Landfills that commenced construction, reconstruction, or modification after 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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5. 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. When Does a Modification Occur?
Construction actually commences on the lateral or vertical expansion
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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7. Legacy NSPS WWW in NESHAP AAAA
Startup, Shutdown, and Malfunction… requires compliance with NSPS Subpart WWW therefore: NESHAP AAAA needs to be revised to reflect XXX
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. Initial Actions Report - Design Capacity Report - NMOC Emission Rate
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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9. Initial Design Capacity Report
Submit
By Nov 28, 2016 for LFs that were constructed, reconstructed, or modified
July 17, August 29, 2016
Within 90 days for affected LFs from the date of the commencement of 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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10. NMOC Emission Rate Report
Submit
By Nov 28, 2016 for LFs that were constructed, reconstructed, or modified
July 17, August 29, 2016
Within 90 days for affected LFs from the date of the commencement of 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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11. Amended Design Capacity Report
Submit
Within 90 days of an  in the max design capacity from < 2.5 MM m3/Mg to > 2.5 MM m3/Mg
(May result from  in the permitted vol or an  in the density)
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12. Thresholds for GCCS Design cap ≥ 2.5 MM Mg & 2.5 ≥ MM m3
NMOC emission ≥ 34 Mg/yr (was 50 Mg/yr)
Install & start the system within 30 months
Industry wants XXX sites to take the entire allowed 30 months before operating the GCCS under XXX. This should allow time for litigation & hopefully allow the agency to provide additional guidance.
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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13. GCCS Design Plan Within 1 yr NMOC ER report ≥ 34 Mg/yr
PE prepares & approves (PE stamped)
Administrator has 90 days to accept PE Stamp or submit design plan for agency for review/approval
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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14. Site-Specific Treatment Monitoring Plan
Sites with LFG treatment must develop site-specific treatment monitoring plan
Submit as part of GCCS Design Plan
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 supersedes 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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15. Site-Specific Treatment Monitoring Plan Example Components
Responsible party (job title) for data collection
Monitoring methods, frequencies, & operating ranges for each monitored operating parameter (based on manufacturer’s recommendations)
Procedures & methods used for QA, maintenance, & repair of all continuous monitoring systems
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16. 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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17. Operating Permit (Title V)
For sites that don’t have an OP, submit:
By Nov 28, 2016 for LFs that were constructed, reconstructed, or modified
July 17, August 29, 2016
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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18. Operating Permit (Title V)
For sites that have an OP, submit modification
If > 3 yr of the permit term remains…
reopen to add new requirements
If < 3 yr of the permit term remains…
address in the renewal application
consult your air permitting agency first !
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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19. Liquids Addition Recordkeeping Example Components
Volume of leachate recirculated*
Volume of all other liquids added*
Sfc area over which the leachate is recirculated
Sfc area over which any other liquids are applied
Total waste in areas w/ recirculated leachate/added liquids*
*records and 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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20. Electronic Reporting Submissions
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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21. Electronic Reporting Links/References
EPA’s Central Data Exchange (CDX) using the Compliance & Emissions Data Reporting Interface (CEDRI)
ERT Users Manual: sers%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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22. Electronic Reporting Electronic Reporting Tool
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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23. Electronic Reporting CEDRI Roles
Preparer Certifier Delegated 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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24. 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 & submits reports to CEDRI & can perform preparer functions
Delegated Certifier: delegated by Certifier to act on 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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25. Electronic Reporting Getting Started
1. Go to
2. Responsible Official registers 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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26. Rule Changes and Industry Impacts
Wellfield Monitoring
Surface Emissions Monitoring
NMOC Emission Demonstrations
Startup, Shutdown, Malfunction
If you were here 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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27. Wellfield Monitoring Schedule & Operational Standards
Monitor N2 or O2 concentration every month
P < 0 at each wellhead, monitor every month
T < 131 F at each wellhead, monitor 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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28. O2 & N2 Monitoring 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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29. Pressure or Temperature Exceedance Initial
If P≥0 or T≥131F initiate corrective action within 5 calendar days
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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30. Pressure or Temperature Exceedance >15 Days
If compliance is not achieved… Conduct a “root cause analysis” & correct as soon as practicable, but not later than 60 days after initial exceedance
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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31. Pressure or Temperature Exceedance >60 Days
If compliance is not achieved… Conduct a “corrective action analysis” & develop an implementation schedule to achieve compliance as soon as practicable, but not later than 120 days following the initial exceedance
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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32. Pressure or Temperature Exceedance >120 Days
If compliance is not 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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33. Root Cause Analysis Definition
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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34. Corrective Action Analysis Definition
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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35. 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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36. 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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37. Surface Emissions Monitoring Example Pattern and Monitoring Points
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.
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38. NMOC Emissions Determination 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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39. Tier 4 Demonstration Optional surface CH4 emissions demonstration
Must be conducted every calendar quarter
Allowed only if LF’s 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 75% of the time (6,570/8,760 hr) preceding the Tier 4 demonstration - during the Tier 4 monitoring, the GCCS must operate as it normally would to collect as much LFG as possible
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40. Rule Changes & 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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41. Startup, Shutdown, Malfunction (SSM)
XXX applies at all times, including periods of SSM
If GCCS is not operating…
The system must be shut down
All valves that could contribute to venting must be closed within 1 hr of GCCS not operating
Keep & submit records of all periods when the GCCS doesn’t operate
Monitoring equipment malfunctions – repair as soon as practicable
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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42. Summary First Actions
For sites that commenced construction, reconstruction, or modification July 17, August 29, 2016
Action
Deadline
Submit Design Capacity Report
November 28, 2016
Submit NMOC Emission Rate Report
Submit GCCS Design Plan
Within 1 yr NMOC ER Report ≥ 34
Perform & Submit Report, Initial Performance Test
Within 180d of required installation date
Complete Site-Specific Treatment Monitoring Plan
By submittal of GCCS Design Plan
Submit Permit Modification to Include NSPS XXX
November 28, 2016 or as required
Begin Recordkeeping for Leachate Recirculation
August 29, 2016
Register for Electronic Reporting (suggested)
1 Month 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.
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43. 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 ER Report ≥ 34
Perform & Submit Report , Initial Performance Test
Within 180d of required install 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 (suggested)
1 Month 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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44. 40 CFR 60 Subpart XXX Regulatory Citations
§ 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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45. 40 CFR 60 Subpart XXX Regulatory Citations (cont.)
§ 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.
© 2017 Cornerstone. All rights reserved.

46. 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.
© 2017 Cornerstone. All rights reserved.