1. Municipal Solid Waste Landfill NSPS/EG Requirements Illinois EPA Bureau of Air Mike Davidson 217/782-2113

2. Important Dates March 12, 1996 March 12, 1996 USEPA Promulgates the NSPS/EG June 17, 1998 June 17, 1998 IEPA Promulgates 35 IAC 220

3. Effect of the NSPS/EG -1 New Media (Air Emissions) to worry about. New Media (Air Emissions) to worry about. Increased Scrutiny of Landfills from a Air Emissions point of View. Increased Scrutiny of Landfills from a Air Emissions point of View. Differing Terminology and Definitions from Land Regulations Differing Terminology and Definitions from Land Regulations New Permit and Regulatory Requirements New Permit and Regulatory Requirements –More Monitoring and Testing –More Records –More Reports

4. Effect of the New Rules -2 Memorialization of Rule Requirements in the Permit Memorialization of Rule Requirements in the Permit Same Source/Collocation Issues Same Source/Collocation Issues

5. Importance of NSPS/EG #1 Applicability: Primary trigger based upon the landfill meeting the Area Source Criteria in 40 CFR 63.1935(a)(3)

6. So Far To Date #1 Illinois EPA has Issued over 70 Title V Permits covering either landfills and/or gas to energy facilities.

7. So Far To Date #2 No sources are classified as being either a major source of HAPs, co- located with a major source of HAPs or being a MSW landfill with a bio-reactor.

8. Importance of NSPS/EG #2 Compliance: Landfills compliance is based upon the NSPS, EG or Approved Alternative as per the NSPS/EG (40 CFR 63.1955(a) or (c))

9. NSPS - Applicability The NSPS applies to MSW landfills for which construction, modification, or reconstruction commences on or after May 30, 1991

10. EG – Applicability #1 MSW landfills for which construction, modification, or reconstruction commences before May 30, 1991 is subject

11. EG – Applicability #2 if the landfill has accepted waste since November 8, 1987, or has additional design capacity available for future waste deposition

12. Title V Requirement June 10, 1996 for MSW landfills that commenced construction, modification, or reconstruction on or after May 30, 1991 but before March 12, 1996; June 10, 1996 for MSW landfills that commenced construction, modification, or reconstruction on or after May 30, 1991 but before March 12, 1996; Ninety days after the date of commenced construction, modification, or reconstruction for MSW landfills that commence construction, modification, or reconstruction on or after March 12, 1996. Ninety days after the date of commenced construction, modification, or reconstruction for MSW landfills that commence construction, modification, or reconstruction on or after March 12, 1996.

13. Control Requirement Design capacities greater than or equal to 2.5 million Mg and 2.5 million m 3 Design capacities greater than or equal to 2.5 million Mg and 2.5 million m 3 NMOC Emissions Greater than 50 Mg/yr NMOC Emissions Greater than 50 Mg/yr

14. NMOC Emissions 40 CFR 60.754(a)(1)(i) 40 CFR 60.754(a)(1)(i) n M NMOC = 2 k L o M i ( e -kt i ) (C NMOC ) (3.6 x10 -9 ) i=1 i=1 40 CFR 60.754(a)(1)(ii) 40 CFR 60.754(a)(1)(ii) M NMOC =2 L o R (e -kc - e -kt ) (C NMOC ) (3.6 x10 -9 )

15. NMOC Emission Rate CAA AP-42

16. Tier 1; 40 CFR 60.754(a)(2) No Testing RequiredNo Testing Required Default Equation Values are UsedDefault Equation Values are Used Calculation & Report Required Within 90 days of being affectedCalculation & Report Required Within 90 days of being affected 40 CFR 60.757(b)(1)(i)(B)

17. Tier 2; 40 CFR 60.754(a)(3) C NMOC Determination Required C NMOC Determination Required Calculation & Report Required Within 180 days after the first 50 Mg exceedance Calculation & Report Required Within 180 days after the first 50 Mg exceedance 40 CFR 60.757(c)(1) 40 CFR 60.757(c)(1)

18. Tier 3; 40 CFR 60.754(a)(4) k Determination Required k Determination Required Calculation uses the Tier 2 C NMOC Calculation uses the Tier 2 C NMOC Calculation & Report Required Within 1 year after the first 50 Mg exceedance Calculation & Report Required Within 1 year after the first 50 Mg exceedance 40 CFR 60.757(c)(2) 40 CFR 60.757(c)(2)

19. GCCS plan Landfill Gas Collection and Control System Design Plan required within 1 year of the first report which the emission rate equals or exceeds 50 Mg per year. 40 CFR 60.752(b)(2)(i) and 60.757(c)

20. Collection System Requirements Maximum gas flow rate Maximum gas flow rate Collect Gas from all areas Collect Gas from all areas – 5 years or more if active; or –2 years or more if closed or at final grade. Sufficient Extract Rate Sufficient Extract Rate Minimize off-site Migration Minimize off-site Migration

21. Control System : #1 Open flare; or Open flare; or A control system designed and operated to reduce NMOC by 98% by weight; or A control system designed and operated to reduce NMOC by 98% by weight; or

22. Control System: #2(a) A enclosed combustor which reduces NMOC by 98 weight percent or reduce the outlet NMOC concentration A enclosed combustor which reduces NMOC by 98 weight percent or reduce the outlet NMOC concentration

23. Control System: #2(b) to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen.

24. Control System: #3 Route the collected gas to a treatment system that processes the collected gas for subsequent sale or use Route the collected gas to a treatment system that processes the collected gas for subsequent sale or use

25. GCCS Startup Installation of Landfill Gas Collection and Control System Completed within 30 months after reporting NMOC emissions 50 Mg/yr 40 CFR 60.752(b)(2)(ii)

26. Reporting Requirements #1 Initial and annual design capacity reportInitial and annual design capacity report NMOC emission reports (Annual or 5 year Reports)NMOC emission reports (Annual or 5 year Reports) Notification of increases in design capacity and NMOC emissionsNotification of increases in design capacity and NMOC emissions

27. Reporting Requirements #2 Submittal of design plans and construction permit applicationsSubmittal of design plans and construction permit applications Compliance certificationsCompliance certifications System Removal ReportsSystem Removal Reports Annual Emission ReportAnnual Emission Report Excavation in Asbestos AreasExcavation in Asbestos Areas

28. Recordkeeping #1 Control and Emission Exceedances Control and Emission Exceedances Location of Asbestos Location of Asbestos Waste Acceptance Rate Waste Acceptance Rate Asbestos Waste Shipment Records Asbestos Waste Shipment Records

29. Recordkeeping #2 Gas Collection and Control Equipment Operating Parameters Gas Collection and Control Equipment Operating Parameters New Well Installation New Well Installation Monitoring Parameters Monitoring Parameters

30. Guidance and Info USEPAs Websites USEPAs Websites NSPS - http://www.epa.gov/ttn/atw/landfill/landflp g.html http://www.epa.gov/ttn/atw/landfill/landflp g.html http://www.epa.gov/ttn/atw/landfill/landflp g.html MACT (AAAA) - http://www.epa.gov/ttn/atw/landfill/lndfillp g.html http://www.epa.gov/ttn/atw/landfill/lndfillp g.html http://www.epa.gov/ttn/atw/landfill/lndfillp g.html USEPA Applicability Determination Index (ADI) http://cfpub.epa.gov/adi/index.cfm http://cfpub.epa.gov/adi/index.cfm