Transcript IEPA Implementation of the New Municipal Solid Waste

Municipal Solid Waste
Landfill NSPS/EG
Requirements
Illinois EPA
Bureau of Air
Mike Davidson
217/782-2113
Important Dates
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March 12, 1996
USEPA Promulgates the
NSPS/EG
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June 17, 1998
IEPA Promulgates 35 IAC 220
Effect of the NSPS/EG -1
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New Media (Air Emissions) to worry about.
Increased Scrutiny of Landfills from a Air
Emissions point of View.
Differing Terminology and Definitions from
Land Regulations
New Permit and Regulatory Requirements
– More Monitoring and Testing
– More Records
– More Reports
Effect of the New Rules -2
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Memorialization of Rule Requirements
in the Permit
Same Source/Collocation Issues
Importance of NSPS/EG #1
Applicability: Primary trigger based
upon the landfill meeting the Area
Source Criteria in 40 CFR
63.1935(a)(3)
So Far To Date #1
Illinois EPA has Issued over
70 Title V Permits covering
either landfills and/or gas to
energy facilities.
So Far To Date #2
No sources are classified as being
either a major source of HAPs, colocated with a major source of
HAPs or being a MSW landfill with
a bio-reactor.
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))
NSPS - Applicability
The NSPS applies to MSW landfills
for which construction,
modification, or reconstruction
commences on or after May 30,
1991
EG – Applicability #1
MSW landfills for which
construction, modification, or
reconstruction commences before
May 30, 1991 is subject
EG – Applicability #2
if the landfill has accepted waste
since November 8, 1987, or has
additional design capacity available
for future waste deposition
Title V Requirement
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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.
Control Requirement
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Design capacities greater than
or equal to 2.5 million Mg and
2.5 million m3
NMOC Emissions Greater than
50 Mg/yr
NMOC Emissions
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40 CFR 60.754(a)(1)(i)
n
MNMOC= 2 k Lo Mi ( e-kti) (CNMOC) (3.6 x10-9)
i=1
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40 CFR 60.754(a)(1)(ii)
MNMOC=2 Lo R (e-kc - e-kt) (CNMOC) (3.6 x10-9)
NMOC Emission Rate
1000.00
CAA
Mg/Yr
100.00
AP-42
10.00
Year
46
20
36
20
26
20
16
20
06
20
96
19
86
19
19
76
1.00
Tier 1; 40 CFR 60.754(a)(2)
• No Testing Required
• Default Equation Values are Used
• Calculation & Report Required
Within 90 days of being affected
40 CFR 60.757(b)(1)(i)(B)
Tier 2; 40 CFR
60.754(a)(3)
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CNMOC Determination Required
Calculation & Report Required
Within 180 days after the first 50 Mg
exceedance
40 CFR 60.757(c)(1)
Tier 3; 40 CFR 60.754(a)(4)
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k Determination Required
Calculation uses the Tier 2 CNMOC
Calculation & Report Required
Within 1 year after the first 50 Mg
exceedance
40 CFR 60.757(c)(2)
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)
Collection System Requirements
 Maximum
gas flow rate
 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
 Minimize off-site Migration
Control System : #1
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Open flare; or
A control system designed and
operated to reduce NMOC by 98%
by weight; or
Control System: #2(a)
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A enclosed combustor which
reduces NMOC by 98 weight
percent or reduce the outlet NMOC
concentration
Control System: #2(b)
to less than 20 parts per million by
volume, dry basis as hexane at 3
percent oxygen.
Control System: #3
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Route the collected gas to a
treatment system that processes the
collected gas for subsequent sale or
use
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)
Reporting Requirements #1
• Initial and annual design capacity
report
• NMOC emission reports (Annual or 5
year Reports)
• Notification of increases in design
capacity and NMOC emissions
Reporting Requirements #2
• Submittal of design plans and
construction permit applications
• Compliance certifications
• System Removal Reports
• Annual Emission Report
• Excavation in Asbestos Areas
Recordkeeping #1
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Control and Emission Exceedances
Location of Asbestos
Waste Acceptance Rate
Asbestos Waste Shipment Records
Recordkeeping #2
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Gas Collection and Control
Equipment Operating Parameters
New Well Installation
Monitoring Parameters
Guidance and Info
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USEPA’s Websites
NSPS http://www.epa.gov/ttn/atw/landfill/landflp
g.html
MACT (AAAA) http://www.epa.gov/ttn/atw/landfill/lndfillp
g.html
USEPA Applicability Determination
Index (ADI)
http://cfpub.epa.gov/adi/index.cfm