Air Quality Regulation Update Presented by Robert E. Dick, PE SWANA Old Dominion Chapter Annual...
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Transcript of Air Quality Regulation Update Presented by Robert E. Dick, PE SWANA Old Dominion Chapter Annual...
Air Quality Regulation Update
Presented by Robert E. Dick, PE
SWANA Old Dominion ChapterAnnual Conference
Wintergreen, VAAugust 7, 2014
Overview
• Proposed NSPS Rule• Advanced Notice of Proposed Rulemaking
(ANPR) – Emissions Guidelines• Supreme Court Decision on GHG Tailoring
Rule• RICE NESHAP Applicability at Landfills• GHG MRR Results
Background on Current NSPS/EG
• Accepted Waste After 11/8/87• Commenced Construction, Reconstruction, or
Modification:– Before 5/30/91, then EG Site subject to
Subpart Cc– After 5/30/91, then NSPS Site subject to
Subpart WWW• NSPS and EG Promulgated in March 1996– EPA is Required to Update every 8 years– EDF sued EPA; CO established deadline
6/30/14• Amendments proposed in 2002 & 2006
never finalized
Current NSPS/EG Affected Facilities
• 1,000 MSW LFs subject to 1996 NSPS/EG
• Administration’s “Climate Action Plan – Strategy to Reduce Methane Emissions” (Methane Strategy)– MSW LFs – 3rd largest source of
anthropogenic CH4– MSW LFs – responsible for 18% of CH4
emissions (2012)
Proposed Rule – NSPS Update
• 7/1/14 – USEPA Issued Notice• 7/17/14 – Published in Federal Register• 9/15/14 – 60-day Public Comment Period
Ends • 3/10/15 – Final Rule Scheduled for
Promulgation• New NSPS Regulation in 40 CFR 60
Subpart XXX• Applies only to MSW LFs that commence
construction, reconstruction, or modification after 7/17/14
Proposed NSPS Changes
Applicability Current NSPS (WWW)
Proposed NSPS (XXX)
Design Capacity 2.5 MM Mg & 2.5 MM m3
2.5 MM Mg & 2.5 MM m3
NMOC Emissions Rate
50 Mg/yr 40 Mg/yr
Installation Timeframe
30 mos. 30 mos.
* Virginia Rule 4-43 assigns different applicability criteria for facilities located within Northern Virginia VOC Non-Attainment Area
NSPS Treatment Systems
• Definition– Absolute filtration rating 10 microns– Water dewpoint of LFG 45°F with
dewatering process– Compression
• Continuous Monitoring – Pressure Drop across Filter– LFG Temperature for chiller-based
dewatering– LFG dew point for non-chiller-based
dewatering• Recording every 15 minutes with hourly and
24-hour block averages
NSPS Changes - SSM Events
• NSPS Standards to apply including SSM Events (current Rule exempts periods of SSM)
• Eliminates the allowable downtime criteria:– 1-hour control device– 5-day collection system
• Must estimate NMOC emissions during downtime
Miscellaneous NSPS Changes
• Criteria for exempting closed areas• Mandates when LF must update GCCS
Design Plan• Clarifies timeframe for submitting
Alternate Timeline Request• Requires Higher Operating Value be
submitted for approval and included in GCCS Design Plan
• All cover penetrations monitored during SEM event
• Clarifies that non-enclosed flares do not have to monitor temperature
Request for Comments
• Utility flares represent BSER• LFG collection from LCRS• Discovery of watered-in wells• Enhanced SEM requirements– Tighter spacing– Integrated sampling
• Use of wellbore seals• Reducing timeframes for initial (30-month)
or expansion (2-year/5-year) GCCS installation
• Use of remote sensing techniques• Possible Tier 4 methodology
ANPR - EG Update
• 7/1/14 – USEPA Issued Notice• 7/17/14 – Published in Federal Register• 9/15/14 – 60-day Public Comment Period
Ends • Not a Proposed Rule; rather requests
information• Would apply to existing MSW LFs that
commenced construction, reconstruction, or modification prior to 7/17/14 (EG Sites and current NSPS Sites)
• Would replace Subparts Cc and WWW
ANPR - EG Update• Should CH4 emission reductions be directly
addressed?• Changes to further reduce LFG emissions:– Reduce/eliminate Design Capacity
threshold– Reducing NMOC emission threshold– Adjust Initial/Expansion times– Use of horizontal collectors for early
control– Adjust duration for system operation
• Enhanced SEM criteria per AB 32 LMR• Early installation of final cover systems• Organics diversion to reduce LFG generation
GHG Tailoring Rule
• 6/23/14 - Supreme Court decision addressing application of PSD/Title V permitting requirements to GHG in Utility Air Regulatory Group v. EPA
• EPA cannot treat GHG as air pollutant for purposes of determining if PSD or Title V permit is required– Sources cannot be subject to PSD/Title
V permit solely based on GHG– Sources subject to PSD/Title V permit
for other pollutants can be subject to BACT for GHG
• EPA lacked authority to “tailor” the CAA
GHG Tailoring RuleBiogenic Deferral
• Supreme Court decision did not directly address DC Court overturning EPA Biogenic Deferral in July 2013
• Deferral decision has not taken effect• 7/21/14 - Biogenic Deferral expired on
own terms• Conclusions:– Unlikely LFs will trigger PSD permits
based on GHG emissions– Expiration of Biogenic Deferral appears
somewhat inconsequential– Critical issue is how EPA considers
fugitive emissions
RICE NESHAP Applicability
• Applicability depends on:– Engine size and type– Construction date, installation date– Facility HAPs status, type of fuel, engine
use, etc.• RICE units at LFs, TS, and MRFs include:– Emergency generators for backup power– Water pumps– Other diesel, gas, propane engines
• Units are typically also subject to RICE NSPS (IIII or JJJJ)
RICE NESHAP Permitting
• VA Article 6 Revisions changed definition of “Non-Road” Engines such that more units considered “Portable” Engines and subject to permitting
• VDEQ DAQ 1/2/14 Memo on Non-Road Engines
• VDEQ fast-track regulatory process to revert definition back to match EPA’s definition
• VA LF air permits may (or may not) include MACT ZZZZ requirements:– Criteria to achieve “emergency” status– Oil & filter change frequency– Non-resettable hour meter
GHG MRR 2012 Results
• MSW LF High = 248,000; Low = 4,300• 9 of the top 11 are the private-sector
regional LFs• 14 of the 41 are below 25,000 MTCO2e
YearMSW LF Total GHG Emissions (MTCO2e)
# of MSW LF
Average GHG per LF (MTCO2e)
Incineration Total GHG Emissions (MTCO2e)
# of Incinerators
Industrial LF Total GHG Emissions (MTCO2e)
# of Industrial LF
Average GHG per LF (MTCO2e)
Total Waste Sector GHG Emissions (MTCO2e)
2010 3,158,722 41 77,042 537,360 4 3,696,082
2011 2,455,171 43 57,097 659,715 4 596,030 6 99,338 3,710,916
2012 2,293,383 41 55,936 677,161 4 597,182 7 85,312 3,567,726
GHG MRR Voodoo
Action Items• Submit request for comment period
extension to EPA• Compile information to address EPA’s
request regarding both NSPS Proposed Rule and ANPR
• Prepare for more stringent Air Quality regulations governing LFG emissions
• Inventory your RICE units (emergency backup generators) and establish applicability and implement compliance monitoring & reporting
• To understand the GHG MRR, see a witch-doctor (or a consultant)