DEQ Landfill Gas Guidance Update and Implementation

Transcription

1 DEQ Landfill Gas Guidance Update and Implementation Priscilla Fisher October 12, 2017

2 Outline Background Navigating the Guidance Monitoring, Remediation, and Return to Compliance Alternate Source Demos Guidance Implementation

3 Background DEQ internal workgroup formed to assess existing landfill gas guidance and tackle historical compliance and permitting issues Updated existing guidance and published interpretative memo clarifying substantial changes in September 2017 Posted on DEQ public website, VA Regulatory Town Hall, and announced via DEQ News Feed ( )

4 Navigating the Guidance Interpretative Memo Submission Instructions for LFG Plans Landfill Gas Exceedances Flowchart Applicable Permit Conditions

5 Quarterly Monitoring At a minimum, landfills are required to monitor for methane gas on a quarterly basis Quarterly = approx. 90 days ( days from prior event) with 1 event per calendar quarter Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Monitor during a variety of weather conditions and barometric pressures Such that there s a greater likelihood of monitoring when the potential for gas migration is higher

6 Compliance Assessments Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec? Missed monitoring within calendar quarter Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Within calendar quarter but over 120 days from prior event

7 Methane Gas Exceedances Action Level Exceedance Compliance Level Exceedance 4% At or above 80% but below 100% of LEL (4 to 4.99% methane) at facility boundary At or above LEL (5% methane) at facility boundary 5% Structures (excluding gas control or recovery system components): at or above 25% of LEL (1.25% methane) Probes in the landfill s perimeter gas monitoring network act as points of compliance to evaluate methane at the facility boundary. GP3 GP1 GP2

8 Methane Gas Exceedances Action level or compliance level exceedances at any probe or structure within the gas monitoring network require remedial actions in accordance with 9 VAC C. Revised Submission Instruction No. 13 clarifies exactly what remedial actions are required to address each exceedance type. GP3 GP1 GP2

9 Action Level Exceedances (4%) Take all steps to protect public health and safety Investigate active & passive gas control and remediation systems Submit written notification within 5 working days Increase gas monitoring frequency (if required) RISK

10 Action Level Exceedances (4%) Protect public health and safety Evacuate occupied structures, if affected Notify local fire/safety officials of potential landfill gas migration Coordinate offsite monitoring of structures located within 1,000 feet of the facility boundary

11 Action Level Exceedances (4%) Investigate gas control and remediation systems Investigate systems for proper connections Adjust vacuum, flow, or control valves Remove condensate Make any other adjustments or repairs necessary to ensure proper operation

12 Action Level Exceedances (4%) Notify DEQ of the Exceedance Notify DEQ within 5 working days Indicate what has been done or is planned to be done to resolve the problem Notification may be submitted via

13 Action Level Exceedances (4%) Increase gas monitoring frequency (if required) Increase monitoring frequency of probe subset if: (1) Offsite receptors are within 1000 ft of the waste management boundary; or (2) Terrain, such as karst topography, or other conduit may provide pathways for migration of landfill gas than can pose hazards to public health and safety and the environment RISK

14 Compliance Level Exceedances (5%) Take all steps to protect public health and safety Investigate active & passive gas control and remediation systems Implement & Submit Gas Remediation Plan 24 hr AND 5 day notifications Increase gas monitoring frequency Assess spacing of probes

15 Compliance Level Exceedances (5%) Implement & Submit Gas Remediation Plan Follow revised Submission Instructions (#13) Describe nature and extent of problem and remedy Include implementation schedule for remedial actions, timeframes for evaluating effectiveness, and milestones for proceeding to next phase Implement & submit to DEQ within 60 days of compliance level exceedance

16 Compliance Level Exceedances (5%) Assess spacing of probes Assess ENTIRE perimeter of landfill gas network If any probes are >250 ft. apart, determine if additional probes are needed to address new or encroaching development Consider adjacent property use, distance to structures, soil/rock conditions, and hydrogeological & hydraulic conditions

17 Gas Probe Spacing Assess probe spacing (entire network) Compliance Level Exceedance

18 Increased Monitoring (Risk-Based) Rural Landfill / No Receptors Urban Landfill / Receptors o Increase monitoring frequency following compliance level exceedances o Conduct MONTHLY monitoring of probe subset until 3 consecutive monthly monitoring events are below action level Probe subset: exceeding probe/structure & at least ONE probe/structure on EACH side of point of exceedance GP3 GP1 GP2

19 Increased Monitoring (Risk-Based) Rural Landfill / No Receptors o Increase monitoring frequency following compliance level exceedances o Conduct MONTHLY monitoring of probe subset until 3 consecutive monthly monitoring events are below action level o Submit monitoring data to DEQ to assess return-to-compliance and resume QUARTERLY monitoring Urban Landfill / Receptors o Increase monitoring frequency following action level OR compliance level exceedances o Conduct WEEKLY monitoring of probe subset until 4 consecutive weekly monitoring events are below action level o Conduct MONTHLY monitoring of probe subset until 3 consecutively monthly monitoring events are below action level GP3 GP1 GP2

20 Notifications & Reporting 1 action level exceedance 5 working days compliance level exceedance 24 hours! shutdowns of active gas control or remediation systems lasting longer than 48 hours other noncompliance or conditions that may endanger health or environment

21 Rural Landfill / No Receptors 5 day written notification Action Level Exceedance

22 Rural Landfill / No Receptors Take steps to protect public health and safety Action Level Exceedance

23 Rural Landfill / No Receptors Take Investigate steps to any protect gas control/remediation public health and systems safety Action Level Exceedance

24 Rural Landfill / No Receptors Take Investigate steps Continue to any protect gas control/remediation QUARTERLY public health monitoring and systems safety Action Level Exceedance

25 Rural Landfill / No Receptors 5 day written notification 24 hr oral notification Compliance Level Exceedance

26 Rural Landfill / No Receptors Take steps to protect public health and safety Compliance Level Exceedance

27 Rural Landfill / No Receptors Take Investigate steps to any protect gas control/remediation public health and systems safety Compliance Level Exceedance

28 Rural Landfill / No Receptors Take Investigate Begin steps MONTHLY to any protect gas control/remediation monitoring public health of probe and systems safety subset Compliance Level Exceedance

29 Rural Landfill / No Receptors Assess probe spacing (entire network) Compliance Level Exceedance Implement & Submit Gas Remediation Plan within 60 days

30 Urban Landfill / Receptors 5 day written notification Action Level Exceedance

31 Urban Landfill / Receptors Take steps to protect public health and safety Action Level Exceedance

32 Urban Landfill / Receptors Take Investigate steps to any protect gas control/remediation public health and systems safety Action Level Exceedance

33 Urban Landfill / Receptors Take Investigate Begin steps WEEKLY to any protect gas control/remediation monitoring public health of probe and systems safety subset Action Level Exceedance

34 Urban Landfill / Receptors 24 hr oral notification 5 day written notification Compliance Level Exceedance

35 Urban Landfill / Receptors Take steps to protect public health and safety Compliance Level Exceedance

36 Urban Landfill / Receptors Take Investigate steps to any protect gas control/remediation public health and systems safety Compliance Level Exceedance

37 Urban Landfill / Receptors Take Investigate steps to any protect gas WEEKLY monitoring control/remediation public health of probe subset and systems safety Compliance Level Exceedance

38 Urban Landfill / Receptors Assess probe spacing (entire network) Compliance Level Exceedance Implement & Submit Gas Remediation Plan within 60 days

39 Return to Compliance Initial Compliance Level Exceedance Gas Remediation Plan Implementation & Assessment Increased Monitoring Ideally, gas remediation should resolve gas exceedances as soon as possible, but problem-solving takes time & money.! Gas concentrations below compliance level < 18 months

40 Alternate Gas Source Demonstrations If proposing an alternate gas source: Provide an ASD work plan in accordance with Submission Instruction 13 prior to sampling. ASD requires gas sampling for fingerprinting and comparison of exceeding probe AND landfill gas sources that are definitively tied to the landfill (extraction wells, leachate collection sumps, etc.) Revised guidance provides consistency for future alternate gas source demonstrations by establishing minimum sampling criteria: Gas fingerprinting analysis for EPA Method TO-15 organics, siloxanes, and sulfur compounds Field comparisons of concentrations of methane, carbon dioxide, oxygen, and gas pressure at each sampling point should be taken Other constituents may be added to the list or substituted based on unique waste types disposed ASD submittal should identify the alternate source of methane.

41 Alternate Gas Source Demonstrations DEQ s assumption (until proved otherwise) is that methane exceedances detected within the monitoring network are originating from the landfill and should be remediated.! alternate source still ONSITE If the alternate gas source is not the landfill itself but is still originating from the landfill s property, the facility is still required to address and remediate the gas exceedances. If the alternate gas source is determined to be from offsite, the property owner of the detected source is responsible for management and remediation. alternate source OFFSITE

42 Guidance Implementation LFG Management & Remediation Plan Updates LFG Plans currently under review Previously approved LFG Plans Update now prior to DEQ approval & permit modification Update during next revision of Gas Management or Gas Remediation Plan If a Compliance Level Exceedance prompts a new or revised Gas Remediation Plan, the plans and permit should be updated for consistency with the new guidance Landfills may still have site-specific permit conditions that should be followed. Compliance Enforcement Compliance changes go into effect January 1, 2018 JAN 1

43 Questions?