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03/14/2017 New Source Performance Standards and Emission Guidelines for Landfills Navigating the Maze The Standards of Performance for Municipal Solid.

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Presentation on theme: "03/14/2017 New Source Performance Standards and Emission Guidelines for Landfills Navigating the Maze The Standards of Performance for Municipal Solid."— Presentation transcript:

1 03/14/2017 New Source Performance Standards and Emission Guidelines for Landfills Navigating the Maze The Standards of Performance for Municipal Solid Waste Landfills (NSPS Subpart XXX) and Emission Guideline (EG, Subpart Cf) were published final on August 29, The NSPS 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 04/04/2017 © 2017 Cornerstone. All rights reserved.

2 Presentation Outline What Landfills are Affected? Rule Mapping
03/14/2017 Presentation Outline What Landfills are Affected? Rule Mapping Legacy NSPS WWW Ref in NESHAP AAAA What Do You Need to Do? 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. © 2017 Cornerstone. All rights reserved.

3 current federal rule (40 CFR § 62 Subpart GGG)
When Were the Rules Published, When Did They Go Into Effect, and What’s Next? When Were the Rules Published, When Did They Go Into Effect, and What’s Next? 03/14/2017 Federal EG in Effect for LFs in States w/o Approved State Plan/Regulation Deadline for States to Submit Plan to EPA XXX/Cf Rules in Effect Final Rules Published 2016 Aug Oct Dec Feb Apr Jun Aug 2017 Today New Jersey may not write a new state rule to implement Cf rules meaning you’d have to defer to current federal rule (40 CFR § 62 Subpart GGG) Subpart GGG is not updated to reflect Cf…yet 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. On August 27, EPA published a new proposed EG for existing landfills- 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 (September 30, 2017) 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. © 2017 Cornerstone. All rights reserved.

4 Who’s Affected by Subpart Cf?
03/14/2017 Who’s Affected by Subpart Cf? Requires States to develop Plans that apply to MSW Landfills that commenced construction, reconstruction, or modification on or before 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) © 2017 Cornerstone. All rights reserved.

5 Who’s Affected by Subpart XXX?
03/14/2017 Who’s Affected by Subpart XXX? 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) © 2017 Cornerstone. All rights reserved.

6 Rule Mapping On or Before July 17, 2014
03/14/2017 Rule Mapping On or Before July 17, 2014 Emissions Guidelines (EG) 40 CFR §§ 60.3c-60.36c 40 CFR §§ 62, Subpart GGG WWW or Cc Cf/GGG OR Closed Cf/GGG Key © 2017 Cornerstone. All rights reserved.

7 Rule Mapping After July 17, 2014
03/14/2017 Rule Mapping After July 17, 2014 New Source Performance Standards (NSPS) 40 CFR §§ WWW (modified LF) XXX OR New XXX Key © 2017 Cornerstone. All rights reserved.

8 03/14/2017 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) © 2017 Cornerstone. All rights reserved.

9 When Does a Modification Occur?
03/14/2017 When Does a Modification Occur? Construction actually begins on the lateral or vertical expansion (“shovel in the ground”) No construction? Need to assess based on site-specific circumstances (i.e. when waste can physically be accepted, approval from state agency) 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) © 2017 Cornerstone. All rights reserved.

10 Legacy NSPS WWW in NESHAP AAAA
03/14/2017 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 BOTH WWW & XXX ! © 2017 Cornerstone. All rights reserved.

11 Initial Actions Report - Design Capacity Report - NMOC Emission Rate
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

12 Reporting Initial Design Capacity/NMOC Emission Rate
03/14/2017 Reporting Initial Design Capacity/NMOC Emission Rate Submit By Nov 28, 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. © 2017 Cornerstone. All rights reserved.

13 Amended Design Capacity Report
03/14/2017 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 © 2017 Cornerstone. All rights reserved.

14 Thresholds for GCCS Design cap ≥ 2.5 MM Mg & ≥ 2.5 MM m3
03/14/2017 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 of ≥ 34 Mg/yr NMOC Report 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 © 2017 Cornerstone. All rights reserved.

15 GCCS Design Plan Within 1 yr NMOC Tier Report ≥ 34 Mg/yr
03/14/2017 GCCS Design Plan Within 1 yr NMOC Tier Report ≥ 34 Mg/yr PE prepares & approves (PE stamped) Administrator has 90 days to accept PE Stamp If not accepted, Administrator submits design plan to 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 © 2017 Cornerstone. All rights reserved.

16 Site-Specific Treatment Monitoring Plan
03/14/2017 Site-Specific Treatment Monitoring Plan Sites with LFG treatment must develop site-specific treatment monitoring plan NSPS XXX/EG does not mention timing NSPS XXX/EG Preamble mentions submittal with Title V Application Requirements become Title V conditions (means they’re federally enforceable) 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. © 2017 Cornerstone. All rights reserved.

17 Site-Specific Treatment Monitoring Plan Example Components
03/14/2017 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 © 2017 Cornerstone. All rights reserved.

18 Initial Performance Test
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

19 Operating Permit (Title V) If you don’t have one  APPLY
03/14/2017 Operating Permit (Title V) If you don’t have one  APPLY 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. © 2017 Cornerstone. All rights reserved.

20 consult your air permitting agency first !
03/14/2017 Operating Permit (Title V) If you do have one  APPLY TO MODIFY (maybe) 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} © 2017 Cornerstone. All rights reserved.

21 Liquids Addition Recordkeeping Example Components
03/14/2017 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 © 2017 Cornerstone. All rights reserved.

22 Electronic Reporting Submissions
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

23 Electronic Reporting Status
03/14/2017 Electronic Reporting Status Submit electronic copies of: Certain required performance test reports (available) NMOC emission rate reports (planned) NSPS Annual reports (planned) Tier 4 emission rate reports (planned) Liquids Addition reports (planned) 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. © 2017 Cornerstone. All rights reserved.

24 Electronic Reporting Links/References
03/14/2017 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) © 2017 Cornerstone. All rights reserved.

25 Electronic Reporting Electronic Reporting Tool
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

26 Electronic Reporting CEDRI Roles
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

27 Electronic Reporting CEDRI Roles
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

28 Electronic Reporting Getting Started
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

29 Rule Changes and Industry Impacts
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

30 Wellfield Monitoring Schedule & Operational Standards
03/14/2017 Wellfield Monitoring Schedule & Operational Standards Monitor Monthly at Each Wellhead N2 or O2 concentration Pressure < 0 Temperature < 131 F 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 © 2017 Cornerstone. All rights reserved.

31 O2 & N2 Monitoring Document any N2 level ≥ 20%
03/14/2017 O2 & N2 Monitoring 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) © 2017 Cornerstone. All rights reserved.

32 Pressure or Temperature Exceedance Initial
03/14/2017 Pressure or Temperature Exceedance Initial If Pressure ≥ 0 or Temperature ≥ 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. © 2017 Cornerstone. All rights reserved.

33 Pressure or Temperature Exceedance >15 Days
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

34 Pressure or Temperature Exceedance >60 Days
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

35 Pressure or Temperature Exceedance >120 Days
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

36 Root Cause Analysis Definition
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

37 Corrective Action Analysis Definition
03/14/2017 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 © 2017 Cornerstone. All rights reserved.

38 Surface Emissions Monitoring
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

39 Surface Emissions Monitoring (cont.)
03/14/2017 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 © 2017 Cornerstone. All rights reserved.

40 Surface Emissions Monitoring Example Pattern and Monitoring Points
03/14/2017 Surface Emissions Monitoring Example Pattern and Monitoring Points This slide shows an example of the serpentine pattern under the old NSPS WWW 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. © 2017 Cornerstone. All rights reserved.

41 NMOC Emissions Determination Tiers
03/14/2017 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… © 2017 Cornerstone. All rights reserved.

42 Tier 4 Demonstration Optional surface CH4 emissions demonstration
03/14/2017 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 © 2017 Cornerstone. All rights reserved.

43 Rule Changes & Industry Impacts
03/14/2017 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… © 2017 Cornerstone. All rights reserved.

44 Startup, Shutdown, Malfunction (SSM)
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

45 03/14/2017 Summary First Actions For sites that commenced construction, reconstruction, or modification July 17, August 29, 2016 Action Deadline Submit Design Capacity /NMOC ER Report November 28, 2016 Submit Operating Permit Application Within 90 days of applicability Submit GCCS Design Plan Within 1 year NMOC Tier Report ≥ 34 Mg/year Perform & Submit Report, Initial Performance Test Within 180 days of required installation date Complete Site-Specific Treatment Monitoring Plan No Timeframe in Regulation. Recommended submittal with 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. © 2017 Cornerstone. All rights reserved.

46 Summary First Actions (cont.)
03/14/2017 Summary First Actions (cont.) For sites that commenced construction, reconstruction, or modification after August 29, 2016 Action Deadline Submit Design Capacity /NMOC ER Report Within 90 days of applicability Submit Operating Permit Application Submit GCCS Design Plan Within 1 year NMOC Tier Report ≥ 34 Mg/year Perform & Submit Report , Initial Performance Test Within 180 days of required installation date Complete Site-Specific Treatment Monitoring Plan No Timeframe in Regulation. Recommended submittal with 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. © 2017 Cornerstone. All rights reserved.

47 40 CFR 60 Subpart XXX Regulatory Citations
03/14/2017 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. © 2017 Cornerstone. All rights reserved.

48 40 CFR 60 Subpart XXX Regulatory Citations (cont.)
03/14/2017 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.

49 Cornerstone Environmental Group, LLC
03/14/2017 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.


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