4 The record articles

New Emission Guidelines and Standards of Performance for Landfills

Posted: November 28th, 2016

Authors: All4 Staff 

New Emission Guidelines (EGs) and Compliance Times for Municipal Solid Waste Landfills (MSW LFs) (Guidelines) and new Standards of Performance for MSW LFs (Standards of Performance) were finalized by U.S. EPA on August 29, 2016 under 40 CFR Part 60, Subparts Cf and XXX, respectively.  Both actions were published in the Federal Register with an effective date of October 28, 2016 as part of President Obama’s Climate Action Plan.

Prior to the recent publication of these two new subparts, regulation of MSW LFs under 40 CFR Part 60 was limited to 1) the Subpart Cc EGs that applied, through U.S. EPA-approved state plans or a Federal plan, to existing MSW LFs for which construction, reconstruction, or modification commenced prior to May 30, 1991 and 2) the Subpart WWW Standards of Performance that applied to MSW LFs that commenced construction, reconstruction, or modification on or after May 30, 1991.  U.S. EPA’s new Subpart Cf assigns EGs, again through U.S. EPA-approved state plans or a Federal plan, to those existing MSW LFs that commenced construction, modification, or reconstruction on or before July 17, 2014 and accepted waste after 1987, while new Subpart XXX assigns Standards of Performance to MSW LFs that commence construction, reconstruction, or modification after July 17, 2014.

For the purpose of this article, since the recently promulgated Subpart Cf EGs apply through U.S. EPA-approved state plans or a Federal plan, we will focus on the impact of the new Subpart XXX Standards of Performance which impact MSW LFs directly.

As compared to the existing Subpart WWW rule format, new Subpart XXX shares overall parallel structure with Subpart WWW, with some distinctions in the details.  Some notable elements of new Subpart XXX are as follows:

  • Thresholds for installing controls, where Subpart XXX reduces the nonmethane organic compounds (NMOC) emissions threshold requiring a Gas Collection and Control System (GCCS) from 50 Mg/year to 34 Mg/year.
  • Emissions threshold determinations, where U.S. EPA has expanded on the Tier 1 through 3 procedures of Subpart WWW by adding a new Tier 4 surface emission monitoring (SEM) demonstration option.
  • Low LFG Producing Areas, where U.S. EPA specifies the criteria for determining when it is appropriate to cap or remove all or a portion of a GCCS.
  • Landfill Gas Treatment, where owners or operators must develop a site-specific LFG treatment system monitoring plan and keep records demonstrating effective monitoring of filtration, de-watering, and compression system performance.
  • Wellhead Operational Standards, where MSW LF owners and operators must monitor and maintain records of monthly nitrogen and oxygen levels.
  • Surface Monitoring, where MSW LFs must conduct quarterly SEM at all cover penetrations and openings within the area where waste has been placed and a GCCS is required.
  • Startup, Shutdown, and Malfunction (SSM), where standards of performance apply at all times, including periods of SSM.

We’re just scratching the surface.  There is a lot more to digest in the recently finalized and already effective rules.  Reach out to ALL4 or Lindsey Kroos at lkroos@all4inc.com or (610) 933-5246 x 122 to discuss how the recently finalized Standards of Performance (and Emission Guidelines) will affect your landfill.


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