Regulatory Update of Air Regulations Impacting MSW Landfills. North Carolina SWANA Fall Conference October 15, 2014 Wrightsville Beach, NC

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1 Regulatory Update of Air Regulations Impacting MSW Landfills North Carolina SWANA Fall Conference October 15, 2014 Wrightsville Beach, NC

2 Today s Topics New Source Performance Standard SWANA Comments Emission Guidelines for Existing Sources Other Regulations

3 New Source Performance Standards (NSPS) for MSW Landfills

4 Timeline of NSPS for MSW Landfills 3/12/96: Subpart WWW Finalized 5/23/02: Proposed Revision 9/8/06: Proposed Revision 10/23/08: Intent to Sue 7/17/14: Subpart XXX Proposed Emission Guidelines ANPRM 9/15/14: Subpart XXX Comment Period Ends 3/30/15: Date to Finalize Subpart XXX

5 Subpart WWW vs. Proposed Subpart XXX Applicability date - landfills that commence construction, reconstruction, or modification after Design Capacity Threshold NMOC emission threshold WWW XXX May 30, 1991 July 17, million Mg & 2.5 million m 3 same 50 Mg/yr 40 Mg/yr

6 Subpart WWW vs. Proposed Subpart XXX initial lag time - time period between when the landfill exceeds the emission rate threshold and when controls are required to be installed and started up expansion lag time - time allotted for the landfill to expand the GCCS into new areas of the landfill WWW XXX 30 months same 5 years for active areas and 2 years for areas that are closed or at final grade same Control System 98% reduction/20 ppmvd same

7 Subpart WWW vs. Proposed Subpart XXX Surface Monitoring Startup, shutdown and malfunction WWW 500 ppm 30 meter intervals apply at all times, except during periods of startup, shutdown, or malfunction, provided that the duration of startup, shutdown, or malfunction shall not exceed 5 days for collection systems and shall not exceed 1 hour for treatment or control devices. [ (e)] XXX same apply at all times, including periods of startup or shutdown, and periods of malfunction

8 Proposed Subpart XXX Landfill Gas Treatment Systems [2002 & 2006] Definition: Filter/De-water/Compress Reduce Water Dew Point to 45 o F Monitor: Temperature or Dew Point Filter < 10 microns Pressure drop across filter Continuous Monitoring Nonproductive Areas (< 1% NMOC) Use Measured closed & separate areas

9 Proposed Subpart XXX Wellhead Standards: temperature, nitrogen/oxygen Alternate submitted for approval Design Plan has to be updated Design Plan Updating Expanding into Area not in Plan [within 90 days] Install/Expand different than in Plan [prior] Implementing Alternate temperature, nitrogen/oxygen [prior] Corrective Action Timeline Requests Request within 15 days of initial exceedance (if won t expand in 120 days)

10 Proposed Subpart XXX NMOC Emissions during Downtime Estimate NMOC emissions Control Device or Collection System is not operating Annual Compliance Report Surface Emission Monitoring Monitor all cover penetrations Electronic Reporting EPA Electronic Reporting Tool (ERT) Only for test methods supported by ERT

11 SWANA Comments to EPA

12 SWANA Comments #1 Design Plan Submittals < 40% of Design Plans approved De Facto Approval Higher Operating Value (HOV) Submit & get approved Submit again in Design Plan & get approved Recommend removal of 3 criteria Well Operated GCCS remove temperature, nitrogen/oxygen Promote more LFG collection from leachate system Helpful at older landfill with declining gas generation

13 SWANA Comments #2 Reduction in NMOC Threshold No technical or scientific justification Cites President s Climate Change Policy Could eventually apply to existing sources Automated Wellhead Monitoring [comment] Not ready for wide-spread implementation Wellfield tuning art and science Surface Emission Monitoring [comment] 30 meter to 25 meter keep as is Alternative Monitoring keep as is

14 Treatment System reduction to 45 F Chiller needed to meet requirement Not always needed Adds significant capital & operating costs Revise definition Startup, Shutdown, & Malfunction Any downtime could lead to enforcement Agency greater leeway Landfills don t shut down need flexibility Assumption of Excess Emissions Problems in calculating emissions SWANA Comments #3

15 SWANA Comments #4 Closed & Non-producing Areas No step down operating or decommissioned Operational standards same for open and closed areas Remove controls 15 years from well installation Alternative Timeline Requests Additional requirements De Facto approval Tier 4 [comment] New Tier for determining timeline of GCCS installation Existing Tiers use generation modeling Incorporates Surface Emission Monitoring

16 SWANA Comments #5 Preventing Waterlogged Wells [comment] Require pumps? Wellfield & SEM sufficient Biocovers & Biofilters [comment] Does mitigate methane and NMOC Limited use no full-scale usage No requirement to use Extension of Comment Period Subpart XXX substantially different Subpart XXX & EG ANPRM at same time

17 Emission Guideline Advanced Notice of Proposed Rulemaking (ANPRM)

18 Existing Source vs. New Source Emission Guidelines Existing Sources EPA Publishes minimum standards (3/12/96) Applicability Accepted waste > 11/8/1987 In operation, constructed/modified < 5/30/1991 States Develop Program Air Quality Rules, 15A NCAC 2D, Section.1700 ANPRM Published July 17, 2014 Proposed by 3/2015 & Finalized by 3/2016

19 Changes in Framework to Reduce Methane Emissions Reduce or REMOVE Design Capacity Threshold More landfills subject to rule 850 of 1,800 under currently Require Title V Permits Calculate & Submit NMOC emissions Reduce NMOC Emission Threshold No more landfill subject to Rule More landfills would have to meet control requirements Reduce Initial & Expansion Lag Times

20 Changes in Framework to Reduce Methane Emissions For Previous 3 items Adjust for Wet Landfills Wet climates or Leachate Recirculation Definition of Wet Landfill Adjust Removal of GCCS Criteria Landfill is closed GCCS in operation for 15 years NMOC emissions below threshold (40 Mg vs 50 Mg)

21 Other Regulations

22 Greenhouse Gas (GHG) Regulation Timeline 4/2/2007: Supreme Court determines EPA has authority to regulate GHG under Clean Air Act 6/3/2010: Tailoring Rule for GHG 1/2/2011: Effective Date of GHG Rule 7/20/2011: 3-Year Deferral of Biogenic CO2 7/12/2013: DC Court vacates 3-Year Deferral 6/23/2014: Supreme Court GHG Decision 7/21/2014: 3-Year Clock ends Rule expires

23 Supreme Court GHG Decision EPA has authority to regulate GHG Impact on Prevention of Significant Deterioration (PSD) PSD Permits NOT required solely based on GHG PSD Anyway sources triggered for another pollutant GHG Best Available Control Technology (BACT) required Impact on Title V Permitting Title V Permits NOT required solely based on GHG Not issue with Landfills

24 Biogenic CO 2 Biogenic CO 2 Emissions at MSW Landfills 1. Fugitive CO 2 from surface of Landfill 2. Pass through CO 2 In collected landfill gas & passes through combustion source* 3. CO 2 from the combustion of Landfill gas in combustion source* EPA Studying Accounting Framework *Combustion source = Flare, Engine, Turbine,

25 Renewable Fuel Standard (RFS) Goal of RFS Reduce petroleum consumption Promotes renewable fuel Reduces Greenhouse Gas (GHG) Renewable Fuel Standard 1 (RFS1) Renewable Fuel Standard 2 (RFS2) Effective 7/1/2010 [40 CFR 80, Subpart M] Through CY Billion gallons in 2022

26 RFS2 New Pathways Approved (7/18/2014) Feedstock: Landfills, WWT Digesters, Agricultural Digesters, Fuel Type: RCNG, RLNG, & renewable electricity Biofuel Category Cellulosic Biofuel is D-Code 3 Gallon Equivalent of Renewable Fuel 77,000 Btu of biogas = one gallon of renewable fuel

27 RFS2 New Pathways Approved Increased Value Biofuel Category Applicable D Code Cellulosic Biofuel 3 or 7 Biomass-Based Diesel 4 or 7 Advanced Biofuel 3, 4, 5, or 7 Total Renewable Fuel 3, 4, 5, 6, or 7 D7 RINs used to meet RVO in all 4 categories D3 & D4 RINs used to meet RVO in 3 of the 4 categories D5 RINs used to meet RVO in 2 of the 4 categories

28 Dave Heitz, P.E. Geosyntec Consultants 104 S Main St., Ste. 115 Greenville, SC dheitz@geosyntec.com