Jacob Shepherd, EIT – SCS Engineers

LFG Regulatory UpdatesMRN/SWANA-MA 2015 Annual Conference

June 26, 2015

Overview

● Proposed NSPS and ANPRMo What could be in the final rule?o What is fair game?

● GHG permitting updates● Proposed NAAQS● Status of AP-42

NSPS REGULATIONS UPDATE

NSPS Regulations Update

● Most recent draft 2006o EPA needs to update every 8 yearso Lawsuit forced EPA to issue proposed rule

● Subpart XXX Proposed Regulationso July 17, 2014o Comments submitted in Septembero Final was scheduled for March 2015o Final rule now expected August 2015

NSPS Regulations Update

● ANPRM released for existing sourceso Comments closed Sept. 2014

● Proposed existing source rule/Final XXX at same time

● Final EG Rule expected March 2016

Proposed Changes

● Size threshold for NSPS unchanged● NMOC threshold from 50 to 40 Mg/yr● GCCS installation timeframe unchanged

o 30 months; 2 year/5 year

● BSER remains a well designed/operated GCCS

Wellhead Monitoring

● Alternate timelineso Exceedance >15do No expansion before 120d

● HOVso Need demonstration

● Design plan updateso Before HOV/Alt Timeline implementationo Different install/expand methodo Design plan still required within 1 year

Tier 2 Sampling

● Sampling before knockouto Negative pressure

● Tier 4o Monitoring w/o GCCSo CA: 200ppm

● Method 18 removed for Tier 2● Method 18 and 25A removed for stack

testing.

http://amiadini.com/NewsletterArchive/111229-NL193NL/envEnl-193_clip_image004.jpg

SSM Exemption

● NSPS now will always applyo Currently not during SSM

● Estimate NMOC during downtime● Report deviations● Elimination of 1 hour/5 day timeframes

SSM Exemption

● Impossible to meeto Temperature

● Landfill emissions not automatic● Valves shut at control devices● Difficult to quantify emission

exceedances● Temperature/downtime deviations?● Fines/enforcement/chronic violations

Closed Area Exemptions

● Nonproductive area exclusion under WWWo Demonstrate <1 percent of total

NMOC

● Under XXX, may use measured gas flowo WWW only modeled/calculatedo Measured gas from closed area onlyo Needs to be physically separated

SEM Monitoring Changes

● At all cap penetrationso Previously, only if observation

● More stringent methods possibleo Tighter monitoring routes (~100ft to 25ft)o Wind restrictions?

● More time, more cost

Gas Treatment

● Not limited to stationary combustiono CNG Stations, High BTU, Industrial Use

● Redefined treatmento 10 micron filtero Dew point down to 45F

● Continuous monitoringo Hourly/24-Hour block averageo Temp. drop / DP drop

● Chillers

Gas Treatment - Comments

● Temp. requirement is increased burden● Pretreatment should be based on

manufacturer guidelines● Chillers represent a major cost

Other Changes - ANPRM

● Dewatering wellso Pumpso Water level measurements

● Gas collection from leachate collectiono Subject to NSPS standards?

● Enhanced seals at wells

Other Changes - ANPRM

● Wet Landfillso Reduced thresholdo Reduced lag times

● Organics diversion & model inputs● Biocovers/biofilters

o Oxidationo Reduce VOC/HAPs/CH4

● Early final cover installation

Other Changes

● Exemption from performance testingo Boilers/process heaters <44MW

● Electronic reporting using CEDRIo Performance testing, NSPS operational reports,

emission rate reportso More accurate?o Save time/money?

NSPS Summary

● Changes are not finalizedo Potential changeso Proposed XXX/EG ANPRM are fair gameo “EPA requests input…” / “EPA is considering…”

● Uncertainty with SSMs● Potential increased costs

o SEMo Design plano Changes to installation/closureo Gas treatment

GHG PERMITTING UPDATE

GH

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e • PSD Permitting– New sources / modifications (major/minor)

– GHGs became regulated pollutants

– EPA proposed GHGs be part of PSD

• Tailoring Rule– Fit PSD to GHGs (75k / CO2e)

• Stepped approach– Step 1: Jan to Jun 2011 (GHG alone cannot trigger)

– Step 2: Jul 2011 to Jun 2013 (GHG alone can trigger)

– Step 3: TBD

• Biogenic deferred – Expired July 2014

GH

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e● SCOTUS decision (June 2014)

o EPA cannot require Title V or PSD solely on GHG Emissions

o Major sources based on criteria pollutants may be required to include GHG in BACT analysis

● EPA Guidanceo No action on sources with GHG in permito Permits will be rescinded/revised

GH

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e● Biogenic emissions

o Not addressed in court decisiono Guidance issued Nov. 2014o BAF factor of zero for landfills

● All CO2 from landfills is biogenico CO2 from combustiono “Pass-Through” CO2o CO2 from methane oxidationo CO2 surface emissionso Industry position = settled

● Fugitive CH4http://www.greenoptimistic.com/wp-content/uploads/2009/10/fart_cow_1.GIF

NAAQS PROPOSED CHANGES

NAAQS Update

● Definition of clean air● Ground-level ozone

o NOx and VOC

● Non-attainment vs. attainmento Current standard 75 ppb (2008)o Review required every 5 years

● Can determine major source/modification

NAAQS Update

● Proposed changeso 70 ppb, but possibly down to 65 ppbo Proposed - 12/17/14, final expected Oct. 2015

● Slightly above background in some cases● More non-attainment

o Potentially more major sources

● Cost of implementation

NAAQS Update - Example

• Current VOC major source limits– Higher pop. counties (ex: Anne Arundel) = 25tpy

– Lower pop. counties (ex: Kent) = 50 tpy

• Example: 75ppb to 70ppb Ozone– Drop to non-attainment?

– No change in 30tpy VOC

– Change from minor to major source

– Lower modelling standards

http://geology.com/topographic-physical-map/maryland.shtml

AP-42 STATUS

AP

-42

Sta

tus

● Landfills are section 2.4o Current version was finalized Nov. 1998o Draft came out in 2008o Use final

● Section 13.5 - Flareso Final section released April 2015o Potential high NOx emission factoro NOx EF remains the same (0.068 lb/MMBtu)o CO EF down from 0.37 to 0.31 lb/MMBtu

QUESTIONSJacob ShepherdSCS Engineers(703) 471-6150jshepherd@scsengineers.com