Transcript MSW NESHAP Control Requirements

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
2.5 million cubic meters and
MSW NESHAP Control
Requirements Contd.
• Estimated uncollected NMOC emissions
 > 50 Mg/yr. Also requires more timely
control of bioreactors
NESHAP Requirements
Beyond the NSPS/EG
1.
2.
Startup, shutdown and malfunction
(SSM) plan and reports
Clarification of monitoring
parameter deviations
NESHAP Requirements
Beyond the NSPS/EG Contd.
3.
4.
Semiannual instead of annual
compliance reports
Timely control of bioreactors
SSM Requirements
Comply with SSM requirements of Part
63 General Provisions, including:
• Develop SSM Plan
• Operate according to SSM Plan
• 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)
SSM Plan Timing
For existing sources, develop plan by:
• January 16, 2004, or
• Date landfill is required to install
GCCS(if later)
Or new landfills, develop plan by date
landfill is required to install GCCS
SSM Plan Requirements
Plan must describe:
• Procedures to operate and maintain the
source during SSM
• Corrective actions for malfunctions
of controls and monitoring equipment
For SSM events:
• Keep records
• If SSM Plan did not address the event,
revise SSM Plan
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 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

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.
Operating Parameter Deviations
(continued)
Deviations occur when:
 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
 Report all deviations in semiannual reports
3. Semiannual Compliance
Reporting
Annual compliance reports
required by the NSPS/EG must be
submitted every 6 months for the
NESHAP
Bioreactor Requirements
NESHAP defines “bioreactor” as a MSW
landfill or portion of a landfill where:
• Any liquid, other than leachate and
condensate, is added in a controlled
fashion to the waste mass (often in
combination with recirculating leachate)
• Minimum average moisture content
> 40 %
• Anaerobic (without oxygen)
USEPA Guidance

Guidance on the NESHAP, SSM plan
development, and bioreactor mass
balance calculations is located on USEPA’s
Air Toxic Website
http://www.epa.gov/ttn/atw/landfill/lndfillpg.html