Where’s the Air in “Landfill”?

1. Where’s the Air in “Landfill”?

2. The Air in “Landfill” Landfill Air Permits Who and Where? 1 2 3 4 • Issues in Permitting • Issues in Compliance Regulations

3. Landfill Air Permits Thirteen active Air Permits for Landfills • One each in Craighead, Fulton, Greene, Jefferson, Prairie, Howard, Saline, Washington, Union, and Yell • Three in Pulaski County • Several coming up for renewal here soon

4. Landfill Air Permits • Landfill Gas Collection systems • Most everyone has one • About half of those who do are voluntary • Two have Landfill to Energy systems • Some send the gas offsite for use • Uncontrolled • Only two

5. Landfill Air Permits All the permits were fairly similar • Landfill emissions, Roads (usually with storage piles, handling), Flares, Engines • Some minor differences in Insignificant Activities and small permitted sources • Storage piles and handling • Solidification of wastes • Engines • Gas Tanks

6. Landfill Air Permits • Compliance conditions • Weigh and throughput • Dust suppression • Flare Monitoring • NMOC reports • Tier II testing • Other Testing • Reporting • SAM and ACC

7. Issues in Air Permitting • Permitting Process in General • Problems and Questions During Review

8. Air Permit Issuance Process

9. Pitfalls in Permitting • Calculations and Assumptions • Landfill itself • LandGem input • Capacity • Cover and Waste acceptance • Tier II sample • Co-disposal • H2S, HAPs, and Air Contaminants • Flares • Include HCl?

10. Pitfalls in Permitting • Calculations and Assumptions • Roads and other Particulate Fugitives • Silt Loading Factor? • Accurate Traffic? • Storage piles ? • Control? • Engines • NSPS or NESHAPs • Emissions and testing • Area vs Major source for HAPs

11. Pitfalls in Permitting • Calculations and Assumptions • Gasoline Tanks • Subject to NESHAP 6C potentially • Total Emissions if using Collection System • Engines and/or Flares complicate the calculation • Area vs Major Source of HAP • Major vs Minor for GHG

12. Pitfalls in Permitting • Modeling • Initial permits • Permits for Public Hearing • Renewals and modifications • There are increases or significantly change the nature of the emissions • Change or a new standard • Significant change to the model

13. Issues in Permitting-Summary • Inconsistency, mistakes, missing information, lack of documentation for assumptions slows the review process down • Total emissions for fee and HAP purposes can be tricky • Less modeling required typically

14. Issues in Compliance • Reporting • Recordkeeping • Monitoring • Other

15. Issues in Compliance • Reporting • Upset Conditions • SAM- Semi Annual Monitoring Reports • General Provision 7 Reports • Know when they are due and don’t be late • Be sure you know what information is necessary and if in doubt, talk to the inspector • ACC- Annual Compliance Certification • General Provision 21 Reports • Line by line certification with the terms and conditions of the permit • Don’t forget Upset Conditions • Again, don’t be late

16. Issues in Compliance • Records • Need ready access to them for inspection purposes • In the units specified by the permit • Some records for 5 years, others for the life of the landfill (General Provision 6 vs NSPS WWW)

17. Issues in Compliance • Monitoring • Be clear on the time interval – daily, continuous, etc • What, where, and units -Incoming waste, Collection System, and Flare and/or Engines

18. Issues in Compliance Other Issues • Renewals • General Provision 3 requires a complete application for permit renewal at least six (6) months before permit expiration • Not merely that it was received, but that it be administratively complete during an in house review • Testing • Should be performed on time • Protocol and sampling should conform to EPA test methods or NSPS requirements

19. Issues in Compliance-Summary • Read and understand your permit • Know what your deadlines are and don’t miss them • Keep your records according to what the permit says • Make sure records are accessible

20. New Regulations • Greenhouse Gas • PM2.5

21. New Regulations-40 CFR Part 98 (GHG) • Subpart A • CH4in amounts equivalent to 25,000 metric tons CO2e or more per year in any calendar year starting in 2010 • Subpart HH – Municipal Solid Waste Landfills • Reporting and Calculation Methodology

22. New Regulations-40 CFR Part 98 (GHG)GHG permitting in Arkansas • Major sources must obtain a Title V permit. • A major source for GHG permitting is one that has the potential to emit 100,000 tpy of CO2e as well as the potential to emit 100 tpy combined of the listed GHGs. • Major new or significantly modified sources are required to obtain permits PSD. • Generally this occurs when there is an increase of at least 75,000 CO2e. • Facilities may request limits on GHG to minor source status. • This may be done by establishing a specific CO2e limit, by limiting individual components of GHGs or by limiting a process throughput such as amount of fuel combusted.

23. New Regulations-40 CFR Part 98 (GHG)GHG permitting in Arkansas • June 22, 2012 , Commission meeting approved revisions to Regulation 19 and 26 relating to greenhouse gases (GHG) • January 11, 2013, EPA published our Draft approval • The comment period ends Feb 11.  • Do not anticipate any comments or issues with final approval

24. New Regulations-40 CFR Part 98 (GHG)GHG permitting in Arkansas • non-PSDTitle V permit • Indicate in the General Information Forms whether or not the facility is a major source for GHG. • No other information is required unless PSD or, if upon review of an application that indicates the facility • PSD for GHG • need to include details on emission rates and other GHG information of these regulations

25. New Regulations – PM2.5 24-hour standard (primary standard) for PM2.5at 35 μg/m3 On Dec. 14, 2012, the U.S. Environmental Protection Agency (EPA) lowered the annual NAAQS for PM2.5 to 12.0 μg/m3 (previously 15.0)

26. New Regulations – PM2.5 From a permitting perspective Incorporating PM2.5 into the Draft Regs 18, 19, and 26 When it will start appearing in permits or be modeled is unknown PSD is another animal