1. MSW NESHAP Control Requirements Contains the same requirements as NSPS/EG. Requires gas collection and control system (GCCS) for same landfill as NSPS/EG Design capacity > 2.5 million MG and Design capacity > 2.5 million MG and 2.5 million cubic meters and

2. MSW NESHAP Control Requirements Contd. Estimated uncollected NMOC emissions Estimated uncollected NMOC emissions > 50 Mg/yr. Also requires more timely control of bioreactors > 50 Mg/yr. Also requires more timely control of bioreactors

3. NESHAP Requirements Beyond the NSPS/EG 1. Startup, shutdown and malfunction (SSM) plan and reports 2. Clarification of monitoring parameter deviations

4. NESHAP Requirements Beyond the NSPS/EG Contd. 3. Semiannual instead of annual compliance reports 4. Timely control of bioreactors

5. SSM Requirements Comply with SSM requirements of Part 63 General Provisions, including: Develop SSM Plan Develop SSM Plan Operate according to SSM Plan Operate according to SSM Plan Record and report SSM events Record and report SSM events (See Table 1 of Subpart AAAA and §§ 63.6(e), 63.10(b)(2), and 63.10(d)(5) of Subpart A)

6. SSM Plan Timing For existing sources, develop plan by: January 16, 2004, or January 16, 2004, or Date landfill is required to install Date landfill is required to install GCCS(if later) GCCS(if later) Or new landfills, develop plan by date landfill is required to install GCCS

7. SSM Plan Requirements Plan must describe: Procedures to operate and maintain the Procedures to operate and maintain the source during SSM source during SSM Corrective actions for malfunctions Corrective actions for malfunctions of controls and monitoring equipment of controls and monitoring equipment For SSM events: For SSM events: Keep records Keep records If SSM Plan did not address the event, If SSM Plan did not address the event, revise SSM Plan revise SSM Plan

8. SSM Reports If actions taken during SSM event were consistent with plan, report event in next semiannual report If actions taken during SSM event were consistent with plan, report event in next semiannual report If actions taken during SSM event were not consistent with plan, report action within 2 days and send letter within 7 days If actions taken during SSM event were not consistent with plan, report action within 2 days and send letter within 7 days If SSM plan is revised, report this in next semiannual report If SSM plan is revised, report this in next semiannual report

9. 2. Operating Parameter Deviations NESHAP requires same monitoring as NSPS/EG Continuous parameter monitoring data for control devices is used to determine compliance with the operating conditions if a deviation occurs, source has failed to meet control device operating conditions.

10. Operating Parameter Deviations (continued) Deviations occur when: Control device operating parameter boundaries in § 60.758© (1) of NSPS are exceeded Control device operating parameter boundaries in § 60.758© (1) of NSPS are exceeded Insufficient data for 1 or more hours in a 3-hour averaging period Insufficient data for 1 or more hours in a 3-hour averaging period Report all deviations in semiannual reports Report all deviations in semiannual reports

11. 3. Semiannual Compliance Reporting Annual compliance reports required by the NSPS/EG must be submitted every 6 months for the NESHAP

12. Bioreactor Requirements NESHAP defines bioreactor as a MSW landfill or portion of a landfill where: Any liquid, other than leachate and Any liquid, other than leachate and condensate, is added in a controlled condensate, is added in a controlled fashion to the waste mass (often in fashion to the waste mass (often in combination with recirculating leachate) combination with recirculating leachate) Minimum average moisture content Minimum average moisture content > 40 % > 40 % Anaerobic (without oxygen) Anaerobic (without oxygen)

13. USEPA Guidance Guidance on the NESHAP, SSM plan development, and bioreactor mass balance calculations is located on USEPAs Air Toxic Website Guidance on the NESHAP, SSM plan development, and bioreactor mass balance calculations is located on USEPAs Air Toxic Website http://www.epa.gov/ttn/atw/landfill/lndfillpg.html