3 2

State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCESCvntt D. B»t*dny, S*cr«twy

Box 7921Mrtton, Wtaconrti 53707TELEFAX NO. 909-297-3979

TOO NO. tOt-267-6897

January 9, 1990 IN REPLY REFER TO: 4440

Mr. Bill G. Constantelos, DirectorWaste Management DivisionU.S. EPA Region V230 South Dearborn StreetChicago, IL 60604 /

SUBJECT: State Applicable, Relevant and Appropriate Requirements(ARAR's) Pertaining to Section 121 of SARARevision #2

Dear Mr. Constantelos:

Enclosed please find the second set of revisions to the comprehensive ARAR'sdocument we provided to you on March 6, 1987 and May 2, 1988. The tables havebeen revised to account for recent rule promulgation and the preparation ofdocuments interpreting rules. Copies of the revisions and the actual revisedrules have been sent to Mr. Jonas Dikinis of your staff for their informationand filing.

Should you have any questions regarding this document, do not hesitate tocontact me or Mr. Gary Edelstein, P.E.. of my staff, at (608) 267-7563.

Sincerely,

Mark F. Giesfeldt/ChiefEnvironmental Response & Repair SectionBureau of Solid & Hazardous Waste Management

MFG:GAE:sbv:\perm\sw98172T.gae

Enc.

-o*4£>Jonas Dikinis - U.S. EPA 5HS/11 (w/enc.)Sue Bangert • SW/3 (w/enc.)Gary Edelstein - SW/3 (w/enc.)District Solid Waste Coordinators (w/enc.)Superfund Program Unit Staff (w/enc.)

232436

LEGALLY APPLICABLE OR RELEVANT AND APPROPRIATESTATE STANDARDS, REQUIREMENTS, CRITERIA AND LIMITATIONS

FOR SUPERFUND PROJECTS IN WISCONSIN

Introdoction

Recent amendments to the Comprehensive Environmental Response and Liability Act (CERCLA,commonly known as Superfund) under the Superfund Amendments and Reauihorization Act of 1986(SARA) included a section on clean-up standards, Section 121. This section requires that any long-termclean-up (i.e., remedial actions) under the Act attain legally applicable or relevant and appropriatestandards, requirements, criteria and limitations (ARAR's) under State and Federal law. State ARAR'smust be met if they are promulgated and legally applicable. If they are not legally applicable to aSuperfund site, but were developed to regulate or protect an environmental media under a differentprogram, they are still considered relevant and appropriate. State ARAR's must be formallypromulgated to be required; they may be waived if they are not consistently applied by the State.

To assist persons (i.e., EPA, their contractors, responsible parties and their contractors) the Bureau ofSolid and Hazardous Waste Management, Department of Natural Resources has prepared thiscomprehensive listing of all promulgated State ARAR's which may apply to Superfund long-term clean-ups. By providing this listing to such persons, Wisconsin is satisfying the requirement of Section 121 toprovide timely notice of the ARAR's.

The comprehensive listing can be easily matched to specific site responses considered through analternatives array in a feasibility study. Therefore, it may be used at any Superfund site in Wisconsin byinterested persons.

Rules, statutes and program requirements are subject to revisions. As the Bureau of Solid andHazardous Waste Management becomes aware of them, this listing will be revised.

Exi*natioa and Use of the

Table 1 is a list of general options for possible remedial actions at Superfund sites. With exception ofitem D. in the table, it is arranged in a 'descending order* of more comprehensive response activities.For example, the options listed under category A are generally "easier* or less involved than, say, theoptions in category C It is also important to note that more comprehensive options, when used at asite, will generally include less comprehensive options as part of a total site remedial action. Forexample, the treatment of hazardous substances in-place (B.I.) will usually include the management ofextracted substances (A.4.) and monitoring (A.1.) as part of an action.

Table 2 matches all promulgated State ARAR's with the general options described in Table 1. Whereno ARAR is given for an option from Table 1, there is no promulgated standard we are aware of. TheTable describes the requirement in a general way, lists any important exceptions and specifies regulatedactivity and media regulated or protected.

Table 3 is a list of construction-related activities associated with the remedial actions listed in Table 1.These activities are not traditionally described in remedial option alternative descriptions, but are oftenencountered at Superfund construction projects, and are subject to State- ARAR's. Often, these activitiesare not identified until detailed design for an action is prepared.

Table 4 matches the promulgated State ARAR's with the construction-related activities described inTable 3. The Table describes the requirements in a general way and any important exceptions.Construction contractors who operate in Wisconsin will usually have a good knowledge of theseARAR's.

o

Appendices 1-10 are the specific requirements, regulations and laws promulgated by the State andadministered by the DNR. The Appendices are arranged by each Department program. The names ofeach specific program contact is provided so interested persons may contact them for further details as aproject progresses. Regulations administered by the Department of Industry, Labor and HumanRelations may be obtained from the Office of Document Sales, P.O. Box 7840, Madison, Wisconsin53707 (608-266-3358).

State Prrmit^ I jcenscs. pi»n Approvals and Other Approvab

In order for the listing to be comprehensive, State permit, approval, license and plan approval ARAR'sare provided. In many instances, technical standards and design or construction requirements areimposed through a license, permit or plan review and approval process. Section 121 of SARA statesthat "on-site" actions are not subject to State "permits". Generally, the Department will require that thenecessary permits, approvals, licenses and plan approvals be obtained. However, some programs canwaive these requirements if the "substantive* technical standards applied through such approvals are met.

yimnmrntal Policy Act

Many DNR decisions, such as permits, license and plan approvals are subject to review under theWisconsin Environmental Policy Act (WEPA), Section 1.11, Stats, and Chapter NR 150, which isprovided in Appendix 10. Department decisions involving Superfund sites could be subject to reviewunder these provisions. For some projects, it is possible that an environmental impact statement wouldhave to be written before the project may proceed. Although it is not entirely clear if WEPA will applyat all Superfund sites, it is necessary to mention it so interested persons have been provided with timelynotice.

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Table 1 - General Options for Remediation(Revised V90)

A. Leave hazardous substances in place; and

1. Monitor

a. Groundwaterb. Airc. Surface water/sedimentsd. Soil gas/subsurface gas migration

1 Contain

a. Cap, cut-off walls; covers

3. Extract Migrating Substances

a. Collection trenches/drainsb. Withdrawal wellsc. Gas collection

4. Manage Extracted Substances (from 3.)

a. Discharge to groundwater, with treatment; without treatment

1) Seepage/ufiltrationApray irrigation2) Injection wells

b. Discharge to surface water; with treatment; without treatment / j

c. Discharge to publicly owned treatment works; with treatment; without treatment

d. Release to air; with treatment; without treatment

1) Vents/flares/stripper tower discharges

e. Residuals; sludges; etc., generated from above • See C

B. Manage hazardous substances in place; and

1. Treat/stabilize

a. Physical treatment/stabilization

1) Vitrification/heat/electrical/microwave, etc

b. Chemical treatment

1) Chemical addition/flushing, etc.

c. Biological treatment

1) In-situ biodegradation•

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C Remove hazardous substances; and

1. Manage on-site

a. Re-disposal; landfill

b. Treat/stabilize

1) Physical treatment/Incineration2) Chemical treatment3) Biological treatment4) Recycle5) Land spread/land treat

c Storage

2, Manage off-site

a. In Wisconsin

1) Landfill2) Treatment - all methods3) Recycle4) Landspread/land treat5) Storage

b. Out-of-State

D. Water Supply (Does not "Remediate1 the Facility Itself)

1. New Public Water Supply

2. New Private Water Supply WeU(s)

3. Treat Public Water Supply

a. Air Stripping Towerb. Activated Carbonc. Other

4. Treat Private Water Supply(s)

a. In-house unit(s)

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Table 2 -

A.I.H.

A. La.

A.I.C.

A.I.C.

A.1.6.

A.la.

A3.b.

A.3.C.

and M«xHa Regulated Of PTOtCCtCd

General Options for Remediation,(Revised 1/90)

Ch. NR 181: Activity - Any disposal or management in surface impoundments orlandfills of hazardous waste (generally, defined the same as RCRA) afterAugust 1, 1981, must meet the closure and long-term care requirements, as well asgroundwater monitoring requirements (See s. NR 181.49) that are generally consistentwith RCRA 40 CFR 264/265 Subpart F. Clean closure or closure as a landfill isrequired for surface impoundments. Media - Soil and groundwater.

Ch. NR 140: Activity - Applies to all Department regulated activities; standardsinclude groundwater monitoring and sampling frequency. Media - Groundwater(standards for groundwater).

Ch. 149: Activity - Use of laboratories for testing of samples from groundwatermonitoring.

Chs. NR 500-520: Activity - Groundwater monitoring at solid waste landfills. See s.NR 508. This also relates to ch. NR 140.

Chs. NR 400-499: Media • Air pollution control standardsChs. NR 445 governs hazardous air pollutant emmisions

Chs. NR 500-520:NR 508.04(3).

Activity - Surface water monitoring at solid waste landfills. See s.

A.4.a.l)

Chs. NR 102, NR 104, NR 105, NR 106 and NR 219: Activity - Streamclassification/standards and sampling/testing methods. Water quality criteria must bemet for surface waters where contaminants from Superfund sites cause exceedences.Discharges from in-place pollutants, such as sediments or contaminated groundwaterare included. Media - Surface water and sediments.

Chs. NR 500-520: Activity • Solid waste disposal landfill gas monitoring standards.See ss. NR 506.07(3), NR 504.04(4)(e) and NR 508.04(2). Media - Landfill gas insoils.

Chs. NR 500-520: Activity • Solid waste disposal landfill cap standards. See ss. NR506.08(3), NR 504.07, Ch. 516 and s. NR 514.07.

Ch. NR 181: Activity - Hazardous waste disposal landfill cap standards. Seess. NR 181.44(12) and (13).

Ch. NR 112: Activity - Any withdrawal well or combination of wells withdrawing 70gpm or greater; standards and approvals. Media - Groundwater (drawdown impacts).

Chs. NR 500-520: Activity - Solid waste disposal landfill gas control standards. Media- Landfill gas in soils and the air. See ss. NR 506.08(6), NR 506.07(3) and NR504.04(4)(e). This also relates to Ch. NR 445, hazardous air pollution controlstandards. See guidances memos relating to solid waste and air pollution control rulesfor further details.

Ch. NR 108: Activity - Wastewater treatment facility plan review and standards.

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c

A.4.a.l) Chs. NR 140, NR 200, NR 214, NR 219 and Ch. 147, Stats.: Activity - Discharge ofwastewater to the land (Le., gronndwater); effluent limits; discharge permits;sampling/testing methods. Media - Groundwater.

A.4.3.2) Ch. NR 112: Activity - Prohibits injection wells of any sort Media - Groundwater.

AAb. Ch. NR 108: Activity - Wastewater treatment facility plan review and standards.

AAb. Chs. NR 102, NR 104, NR 105, NR 106, NR 200, NR 219 and NR 217 and Ch. 147,Stats.: Activity • Discharge of wastewater to surface waters; effluent limits; dischargepermits; sampling/testing methods. Media - Surface water.

A.4.C. Ch. NR 108: Activity - Wastewater pretreatment facility plan review and standards.

AAc. Ch. NR 211 and Ch. 147, Stats.: Activity - Discharge of wastewater to publicly ownedtreatment works; effluent limits. Media - Discharges from publicly owned treatmentworks • surface water/groundwater.

AAd.1) Chs. 400-499: Media - Air pollution control standards.Ch. NR 445 governs hazardous air pollutant emissions.

A.4.C. See C

B.l.b. Chs. NR 112, NR 140, NR 200, NR 214, NR 219 and Ch. 147, Stats,: Activity -Discharge of wastewater to the land (Le., groundwater, provided that a discharge tocarry chemicals is used). Use of injection wells of any sort to inject chemicals isprohibited. Media - Groundwater.

B.I.C. Same as B.l.b., but applies to nutrients as well as any chemicals.

C.1.&2. Chs. NR 157, NR 500-520, NR 181 and s. 144.79, Stats.: Activity - Management ofPCB contaminated wastes. The treatment, storage, disposal and transportation of PCBwastes are subject to special State requirements and standards. Generally, thestandards applied to wastes of concentrations greater than 50 ppm of PCBs follow thefederal requirements. For wastes containing less than 50 ppm of PCBs, see the specialguidance document in Appendix 3, which is a restatement and clarification ofpromulgated State standards. Media - Groundwater, soil and air.

Cl.a. Chs. NR 500-520 and s. 144.44, Stats.: Activity - Solid waste disposal licensing process,plan review and standards. Standards are applied through plan review and a sitingprocess which involves local governments and a State siting board. Media -Groundwater, soil

C.IA. Ch. NR 181 and s. 144.44, Stats.: Activity - Hazardous waste disposal licensingprocess, plan review and standards. Standards are applied through plan review and asiting process which involves local governments and a State siting board. Media -Groundwater, soil.

C.l.b.1), Ch. NR 181: Activity - Hazardous waste treatment (includes incineration) facilities are2)3) subject to a licensing process, plan review and standards. For new facilities, standards

are applied through plan review and a siting process which involves local governmentsand a State siting board. Systems for treating wastewater which discharge to surfacewater, grouadwater, or a poblidy owned treatment works pursuant to Ch. 147, Stats.,fall under A. or B., above. Media - Air, groundwater and soil

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Cl.b.l)

Cl.b.4)

Cl.b.5)

Cl.b.5)

C.I.C.

C2.

Cla.1)

Cla.1)

Cla.2)

C2.a.2)

Chs. 400-499: Activity - Emissions from treatment systems/incinerators. Media - Airpollution control Ch. NR 445 governs hazardous air pollutant emissions.

Co. NR 181: Activity • Recycling of hazardous waste requires a special writtenexemption. Standards are applied through plan review of the exemption requestMedia - Groundwater and soil

Ch. NR 181: Activity - Land treatment of hazardous waste is prohibited. Media -Groundwater and soil

Chs. NR 140, NR 214, NR 200 and NR 219: Activity • Landspreading of wastewatertreatment facility sludges (nonhazardous waste sludges) is regulated under thewastewater program rules. Media - Groundwater and soil

Ch. NR 181: Activity - Hazardous waste storage facilities are subject to a licensingprocess, plan review and standards. For new facilities, standards are applied throughplan review and a siting process involving local governments and a State siting board.Media - Groundwater and soil.

Ch. NR 181: Activity - Generation and transportation standards for hazardous wasteare specified. They are based on RCRA standards. Manifests must be used forhazardous waste shipments. Transporters must be licensed to haul hazardous waste.

Chs. NR 500-520 and s. 144.44, Stats.: Activity - Solid waste disposal licensing process,plan review and standards. For new sites, standards are applied through plan reviewand siting process which involves local governments and a State siting board. Existingsites must be given special one-time waste disposal approval for solid (nonhazardous)waste disposal (See ss. NR 506.09 through NR 506.14). Media - Groundwater andsoil

Ch. NR 181 and s. 144.44, Stats.: Activity - Hazardous waste .disposal licensingprocess, plan review and standards. For new sites, standards are applied through planreview and siting process which involves local governments and a State siting board.There are currently no existing commercially available sites for hazardous waste landdisposal in the State of Wisconsin. Media - Groundwater and soiL

Ch. NR 181: Activity - Hazardous waste treatment (includes incineration) facilities aresubject to a licensing process, plan review and standards. For new facilities, standardsare applied through a siting process involving local governments and a State sitingboard. Existing commercially available treatment facilities must be approved (throughmodification of their existing licenses) for acceptance of new waste streams they arenot already approved to accept Systems for treating wastewater which discharges tosurface water, groundwater or a publicly owned treatment works, pursuant to Ch. 147,Stats., fall under A. or B., above. Media - Air, groundwater and soiL

Chs. 400-499: Activity - Emissions from treatment systems. Media - Air pollutioncontrol. Ch. NR 445 governs hazardous air pollutant emissions.

Ch. NR 181: Activity - Recycling of hazardous waste requires a special writtenexemption. Standards are applied through plan review of the exemption requestExisting, commercially available recycling facilities must be approved (throughmodification of their existing written exemption) for acceptance of new waste streamsthey are not already approved to accept Off-site storage licensing may also apply.Media - Groundwater and soiL

7 -

Ch. NR 181: Activity • Land treatment of hazardous waste is prohibited. Media -Groundwater and sou.

CZ.a.4) Chs. NR 140, NR 214, NR 200 and NR 219: Activity • Landspreading of wastewatertreatment facility sludges (nonhazardous waste sludges) is regulated under thewastewater program rules. Media - Groundwater and soil

C2.3.5) Ch. NR 181: Activity - Hazardous waste storage facilities are subject to a licensingprocess, plan review and standards. For new facilities, standards are applied through asiting process involving local governments and a State siting board. Basting,commercially available storage frailties must be approved (through modification oftheir existing licenses) for acceptance of new waste types they are not already licensedto accept Media - Groundwater and soil

O.I. See Tables 3 and 4, item B.I.

D.2. See Tables 3 and 4, item 8,1-a.

D3. See Tables 3 and 4, item B.I.*.

D_3.a. Activity - Stripper discharges: See AAd.

D3.b. Activity • Spent Carbon: See C

D3.C. Activity - Other treatment residuals: See C

D.4. Ch. NR 112: Activity - In-house treatment units must be approved by the Department.See ss. NR 112.15(5) and (6). The property owner is responsible for obtaining theapproval As a matter of policy, the Department will only approve such systems as amethod of last resort

D.4. Chs. ILHR 81-84 (Uniform Plumbing Code): Activity - Plumbing system plans for in-house treatment units must be approved by DILHR. Only DILHR-approved productsmay be used in such systems. Products must have prior, separate approval Theplumbing code contains technical standards the system must conform to.

D.4. Activity - Spend carbon or other residuals from home treatment units: See CHousehold waste may not be subject to ch. NR 181 requirements.

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Table 3 - Construction Related Activities AssociatedWith Options for Remediation

A. Construction Dewatering

1. Withdrawal wells

a. Discharge to groundwater or surface water of withdrawn water, treated; untreated

2. Other methods of dewatering

a. Discharge to groundwater or surface water of withdrawn water, treated; untreated

B. Water Supply

1. Potable supply

a. Well(s)b. Surface water withdrawal

2. Nonpotable supply

a. Well(s)b. Surface water withdrawal

C Sewage/Sanitary Disposal

1. Discharge to surface water - with treatment2. Discharge to groundwater • with treatment3. Septic systems/holding tanks4. Hook-up to local sewers5. Landspreading/septage

D. Solid Waste Disposal/Dredge Spoil Disposal

1. On-site2. Off-site

E. Buildings/Struaures/Equipment

1. Tanks - flammable materials

a. Below groundb. Above ground

2. Plumbing

3. Structures

4. Boilers/pressure vessels

5. Refrigeration

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o

F. Floodplain/Shoreland Activities

1. Any construction in the floodplain

a. Incorporated areas, including wetlandsb. Unincorporated areasc. St. Croix River .

G. Surface Water/Sediment Management and Structures

1. Dredging2. Surface water rerouting3. Pond construction4. Filling5. Dams6. Bridges7. Any other structure

H. Wetland/Shoreland Activities

1. Dredging/removal2. Filling

I. Spills of Hazardous Materials

J. Safety in the Work Place

1. Trenches, excavations and tunnels2. Noise3. Compressed air4. Illumination5. Fire prevention6. Dust, fumes, vapors and gases7. Spray coatings

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Table 4 - Promolotcd S>ai"tards/ReqnirenientsConstruction Regulated Activities

with Ootioitt for Remediation(Revised 1/90)

A.1. Ch. NR 112: Any withdrawal well or combination of wells withdrawing 70 GPM orgreater; standards and approvals.

ALa. Chs. NR 102, NR 104, NR 105, NR 106, NR 200, NR 217, NR 219 and Ch. 147,Stats.: Discharge of wastewater to surface waters; effluent limits; discharge permits;sampling/testing methods. If no pollutants are to be discharged, several of theserequirements can be waived.

A. La. Chs. NR 112, NR 140, NR 200, NR 214. NR 219 and Ch. 147, Stats.: Discharge ofwastewater to land (i.e., groundwater). Use of injection wells of any son is prohibited.Effluent limits; discharge permits; sampling/testing methods. If no pollutants are to bedischarged several of these requirements may be waived.

A. La. Ch. NR 108: Treatment facility (if needed to meet effluent limits) plan review andstandards.

A2a. Same as Ala.

B.l.a. Chs. NR 111, NR 112, NR 108 and NR 109: Potable well construction for allapplications must meet the Ch. NR 112 construction and design standards. For anyapplication withdrawing 70 GPM or more, standards and approvals are required underCh. NR 112. Wells, treatment and distribution systems for community and municipalwater supplies must meet the construction and design standards in Ch. NR 111, andare subject to the plan approval requirements of Ch. NR 108. Potable water qualitymust meet Chapter NR 109 standards. /*"\

B.l.b. Chs. NR 111, NR 112, NR 108 and NR 109: Surface waters may not be used forprivate water supplies in accordance with Ch. NR 112, nor for community supplies perNR 111. They may be used for municipal water supplies; such systems utilizing surfacewater for a source are subject to the design and construction standards in NR 111,plan approval under NR 108 and the water quality standards in NR 109.

B.2.3. Ch. NR 112: Wells for all applications must meet Ch. NR 112 construction anddesign standards. Any applications withdrawing 70 GPM or more are subject tostandards and approvals.

C.1.&2. Chs. NR 110, NR 104, NR 105, NR 106, NR 210, NR 214 and NR 219: Generally,separate sewage treatment facilities are prohibited unless determined to be necessaryunder s. NR 110.08(5)(c). If allowed, plans and reports are required under Ch. NR110. Effluent limits, permits and sampling/analysis requirements apply under the otherrules. Land application is regulated under Ch. NR 214:

C3.&4. Chs. ILHR81-84: Plumbing code requirements apply to the design and construction ofseptic systems, holding tanks and lateral connections to public sewer systems.

C.5. Ch. NR 113: Septage and holding tank hauling and landspreading requirements,licenses and approvals.

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D.1.&2. Ch. 147, Stats.: Confined dredge disposal areas adjacent to surface waters areregulated through a wastewater permit. Plan review, construction and designrequirements apply.

D.I. Chs. NR 500-520 and ss. 144.436 and 144.44, Stats., Solid waste disposal landfillslicensing process, plan review and standards. Standards are applied through planreview and a siting process than involves local governments and a State siting board.Generally, involves local governments and a State siting board. Generally, under s.144.436, Stats., open burning of solid waste is prohibited.

D.I Chs. NR 500-520 and s. 144.44, Stats.: Same as D.I. Off-site commercial or municipallandfills may need a special approval (plan modification) to accept special(nongarbage) wastes. See ss. NR 506.09 through 506.14.

El. Ch. IND 8: Tanks, including underground tanks, standards and design.

E.Z Chs. ELHR81-84: Plumbing code (see C3. and 4.).

E3. Chs. ILHR50-53 and 64: Building code - design, standards, construction, etc.

E.4. Chs. ILHR41 and 42: Boiler and pressure vessel design, standards, construction, etc.

E_5. ILHR45: Refrigeration design and standards.

F.I. Ch. NR 116: Regulates all construction activities in the floodplain (generally, the 100-year floodplain). Any construction activity must be evaluated for impact on upstreamflooding. Generally, no activities are allowed in the "floodway", including solid orhazardous waste disposal

F.I.a. Ch. NR 117: Requirements (implemented by local zoning) for floodplain activities inincorporated areas.

F.l.b. Ch. NR 115: Requirements for floodplain activities in unincorporated areas.

F.l.c. Ch. NR 118: Requirements for floodplain activities in the St. Crbix basin.

G.I. Chs. NR 345-347 and Chapter 30, Stats.: Permits, approvals and technical standardsfor dredging activities. See the dredge spoil disposal requirements (D., above).

G.2. Ch. 30, Stats.: Permits, approvals, technical standards.

G.3. Ch. 30, Stats.: Permits, approvals, technical standards (if connected to, or within 500feet of a stream).

G.4. Ch. 30, Stats.: Generally, this activity is prohibited, except for structures.

G.5. Ch. NR 333 and Ch. 31, Stats.: Permits, approvals and standards for construction.

G.6. Ch. NR 320 and Chs. 30 and 31, Stats.: Permits, approvals and standards.

G.7. Chs 30 and 31, Stats.: Permits, approvals and technical standards.

H.2. Chs. NR 115-117: Regulates filling in wetlands that are in the shoreland zone.Generally, implemented by local xming.

12-

L Ch. 144.76, Stats, and Chs. NR 158: Spill law. Requires reporting and clean-up ofspills of any hazardous substance.

J. Ch. IND1: General safety requirements.

J.I. Ch. IND6: Safety requirements for trenches, excavations and tunnels.

J.2. Ch, IND11: Safety requirements for noise protection.

J.3. Ch. IND12: Safety requirements for compressed air.

J.4. Ch. IND19: Safety requirements related to illumination.

JJ. Ch. IND65: Safety requirements for fire prevention.

J.6. Ch. IND220: Safety requirements for dust, fumes, vapors and gases.

J.7. Ch. IND221: Safety requirements for spray coating operations.

o

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Appendix 1 - General/Permit Primer

Appendix 2 - Water Resources Program Rate

Chapter MR 140/Groundwater QualityContact: David Lmdorff, 266-9265/Kevin Kessler, 267-9350

Chapter NR 102 - Water Quality Standards for Surface Waters

Chapter NR 104 - Classification Standards

Chapter NR 105 - Surface Water Quality Criteria for Toxic Substances

Chapter NR 106 - Procedures for Calculating Toxic Effluent LimitsContact: Duane Schuettpelz, 266-0156

Appendix 3 - Solid Wntti*/F^*7*rTto^n Waste Pro*r*m

Chapter NR 157 - PCBsContact: Mark Tusler, 266-5798

Chapter NR 158 - SpillsContact: Kim McCutcheon, 266-2857 (This program however, is decentralized to the DNR Districts)

Chapter NR 500-520 - Solid WasteContact: Lakshmi Sridharan, 266-0520

Chapter NR 181 - Hazardous Waste (to be renumbers NR 600-699 in futureContact: Barbara Zellmer, 266-7055

Chapter NR 550 - Environmental Response and RepairContact: Mark Giesfeldt, 267-7562

Chapter NR 144, Stats., - Solid Waste, Hazardous Waste, PCBs, and Spills

PCB Guidance (Based on promulgated rules and Statutes)Contact: Mark Tusler, 266-5798

Monitoring Well Construction (Guidance only)

Groundwater Sampling Procedures (two portions-Guidance only, not promulgated).Contact: Jack Connelly, 267-7574

Appendix 4 - Wastewater Program

General ExplanationContact: Ken Wiesner, 266-0014

Chapter NR 108 - Plan Approvals

Chapter NR 200 - Wastewater Permit Applications

Chapter NR 211 - Pretreatment

Chapter NR 214 - Land Application

- 14-

Chapter NR 217 - Uncategorized Sources

Chapter NR 219 - Test Methods

Section 144.04, Stats. • Plan Approvals

Chapter 147, Stats. - Wastewater Program Statute

Appendix S - Air Pro€p"n Rules

Chapters NR 400-499, Air Pollution ControlContact: Pat Kirsop, 266-2060

Appendix 6 - Water Supply Program Rules

Chapter NR 108 - Plan Approvals

Chapter NR 109 - Safe Drinking Water

Chapter NR 111 - Community Water SystemsContact: Robert Baumeister, 266-2299

Chapter NR 112 - Well ConstructionContact: BUI Rock, 267-7649

Chapter NR 110 - Sewage SystemsContact: Chuck Burney, 266-2304

Chapter NR 113 - Servicing Septic/Holding TanksContact: Bob Steindort 266-0449

Chapter NR 210 - Effluent Limits for Sewage Treatment Works

Appendix 8 - Technical ^ruir^ Program Rules

O

Chapter NR 149 - Lab CertificationContact: Ron Arneson, 267-7633

Appendix 9 - Water Rccr^tlott »«««i Zn**^* Rules gt** Statutes

Chapter NR 115 - Shoreland Management

Chapter NR 116 - Floodplain Management

Chapter NR 117 - City/Village Program

Chapter NR 118 - SL Crone River

Chapter NR 320 - Bridges

Chapter NR 333 - Dams

- 15 -

Chapter NR 340 - Waterway Construction

Chapter 345 - Waterway Beds Construction

Chapter NR 346 - Fees

Chapter NR 347 - Dredging Project

Chapter 30, Stats.

Chapter 31, Stats.Contact: Scott Hausmann, 266-7360

(This program, however, is mostly decentralized to the DNR district offices).

Appendix 10 - EnviromngBtai lmn>n Rales

Chapter NR 150 - Environmental Analysis and ReviewContact: Roger Fritz, 266-1201

of Industry. T a**nr A Human RelitioBt Rulci

Copies of these codes are available through: Document Sales - Department of Administration, P.O. Box7840, Madison, WI 53707, 266-3358Contacts: Ron Buchholtz, 266-9420

Loretta Trapp, 266-2990 (Home treatment units)

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Enclosures for Update #3:

1. Revised NR 102-Add to Appendix 2.

2. NR 105 • Surface Water Quality Criteria for Toxic Substances • Add to Appendix 2.

3. NR 106 - Procedures for Calculating Toxic Effluent Limits - Add to Appendix 2.

4. Memorandum dated 9/27/89 - Guidance on how Solid Waste Rules apply to landfill gas emissioncontrol - Add to Appendix 3.

5. NR 445 • Control of Hazardous Pollutants - Add to Appendix 5.

6. Memorandum dated 11/17/89 - Guidance on Compliance with NR 445 for landfill gas emissions -Add to Appendix 5.

7. Groundwater Sampling Procedures Field Manual, Final - Add to Appendix 3 (Replace draftversion).

v:\penn\sw98172tgae(Revised 1/90)

O

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• A O - 7 5 )

STATE OF WISCONSIN

Date:

To:

From:

September 27, 1989

Mark Giesfeldt - SW/3

u, (.-***

Fi*M: 4440

lakshmv-Sfidharan - SW/3

Landf111 Gas Emiss1ons

In a May 4, 1989 memo, you asked that our Section provide guidance regardinghazardous air contaminant control requirements contained 1n Chs. NR 500-520.Below are your basic questions followed by our responses:

1. "What types of gas collection systems are acceptable to meet the Intentof the rule, and are different types of systems acceptable at differentkinds of sites?"

oNR 506.08(6) requires that, unless an owner can demonstrate that theperformance criteria of s. NR 504. 04(4) (f) can be achieved without sucha system, all sites which have a design capacity of over 500,000 cubicyards and which have accepted municipal solid waste must Install asystem to efficiently collect and combust hazardous air contaminants.We believe that only active systems are capable of efficientlycollecting landfill gas at sites of this size. No type of passivesystem would be acceptable. In general, an active system would berequired to contain the following basic elements:

- A series of vertical extraction wells Installed to the base ofthe landfill which are spaced on a 100 to 300-foot griddepending on individual site characteristics

- A header pipe which connects all the extraction wells and routesthe landfill gas to the blower

- A blower capable of producing a vacuum of at least severalinches water column in the extraction well furthest from it.

- A system to collect all gas condensate produced and which allowsfor its removal and treatment

A flare which efficiently combusts any hazardous aircontaminants present in the gas

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2. "If a new NR 504 cap 1s being Installed on an old abandoned municipalco-disposal site that already has some passive gas collection, is a newgas collection system still required to meet the intent of the rule andif so, what type? Given the language in s. NR 504.07(3), is a new gasventing layer also required at such a site, if a new cap is planned?"

Regardless of whether a new cap is required or whether a passive systemcurrently exists, a site falling under the criteria of NR 506.08(6)would be required to install an active gas extraction system. Fortechnical reasons, combining active and passive systems on the same sitewould not be acceptable. The vacuum created by the active system'sblower would likely cause excessive air intrusion through the passivesystem's vents. Such an occurence would reduce the effectiveness of theactive system and could cause landfill fires.

Regarding the second part of your question, for sites with an active gasextraction system, the gas venting layer of an "NR 504 cap" is notnecessary and could be omitted.

3. "For the site in 12, can an owner/operator/responsible party (RP) testout of the flaring requirement by sampling the existing passive ventingsystem which could be replaced, or should the new system be testedinstead? The new system will likely collect more gas so the testingresults from the existing system won't be the same as for the newsystem."

Because of the siginificant costs Involved with the gas extractionsystem itself, we would envision that any attempts at testing out of therequirements for control of hazardous air contaminants would occurbefore any portion of an extraction/combustion system was constructed.For such a situation, sampling of an existing passive venting systemwould not be an acceptable method of attempting to test out of therequirements primarily because it would not provide a representativesample of all the gas produced by the landfill, Also, it would provideno Information on gas production rates which are necessary to determineif the emission rates in NR 445 are exceeded.

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4. "If an owner/operator/RP plans to test out of the flaring requirement,does the August 1, 1989 deadline In s. NR 506.08(6) apply 1f the testingIs still ongoing on that date? Also, does that date apply 1f 1t will beimpossible to complete construction because of delays associated withthe Superfund process? It 1s unrealistic to assume that the remedy atMid-State and a number of other sites will be constructed by that date."

The method we intend to specify for attempting to test out of therequirements for the control of hazardous air contaminants will likelyinvolve a sampling period that can last up to five years. Therefore,the August 1, 1989 date will not apply to those sites which areattempting to test out using our prescribed method. We do not intend toactively enforce the August 1, 1989 date for sites that we believe aremaking a concerted effort to comply with the new requirements forcontrol of hazardous air contaminants.

It would seem to us that decisions involving enforcement of the date forSuperfund sites should be made on a case-by-case basis depending on theperceived severity of the problem and the anticipated length of delays.However, we believe that installation of an active gas system would nothave a.significant effect on any potential remedial actions that maysubsequently be required after completion of the Superfundinvestigation.

I hope that this memo has adequately answered your questions. If you wouldlike to discuss this issue further, please contact Dennis Hack or GeneMitchell.

dpm

cc: Pat Kirsop - AM/3Chuck Leveque - LC/5Sue Bangert - SU/3Gary Edelstein - SW/3Solid Waste Unit LeadersDennis Mack - SW/3Paul P. Di dier - SU/3

STATE OF WISCONSIN

November 17, 1989 f/>/»«/.- 4530

Paul P. Dldier - SW/3

Donald F. Theller - AM/3 /

V"Sub'ect Landfill Gas Emissions and Compliance With Chapter NR 445, Wis. Adm. Code

This memorandum 1s 1n response to requests made by Hark Glesfeldt of yourstaff for guidance relating to how Chapter NR 445 (Control of HazardousPollutants! Impacts Superfund landfill sites. Four Issues were Identified byMark which are repeated and responded to below.

1. Chapter NR 445 has differing requirements for new and existing sources.Are landfills new or existing sources?

Sources constructed, or modified 1n such a way so as to Increase potentialemissions, after October 1, 1988, are new or modified sources subject to s. NR445.04. Remedial actions at Superfund sites nay be viewed as modifications

O which result In increased emissions. Sources constructed or last modifiedbefore October 1, 1988 are existing sources subject to s. NR 445.05.

2. Under s. NR 506.08(6), landfills (municipal waste) over 500,000 cubicyards must meet the NR 445 limits/standards or flare by August 1, 1989.Does Chapter NR 445 require small landfills to meet the limits/standardsas well? If so by which dates?

Chapter NR 445 contains no specific exemptions for landfills. Any. existinglandfill is considered to be a potential source of hazardous air emissions.This includes both Superfund and non-superfund landfills smaller than 500,000cubic yards. However, we do not expect that emissions from small municipallandfills which are not actively vented to the atmosphere will be of anysignificance. The rule establishes schedules for existing sources to achievecompliance which Include notification and plan submlttal requirements. Thedate by which compliance must be achieved depends on the type and quantity ofpollutants being emitted. These schedules, including the dates by whichcompliance must be achieved, are detailed in ss. NR 445.05(6) and (7). New ormodified sources must be able to comply with s. NR 445.04 upon startingoperation.

We do not intend to make any extraordinary information, education orimplementation efforts with respect to small landfills. Compliance decisionswill be made on a case-by-case basis depending on the seriousness of thepotential problems and in conjunction with any enforcement actions beingpursued under other programs as appropriate.

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3. Testing/Monitoring:

a. Clear guidance on methods/techniques to test out of the NR 500flaring requirement Is requested.

Dennis Mack of your bureau's Solid Waste Section developed the guidanceidentified as Attachment I with Input from air management program staff. Thesampling and analysis guidance Identified as Attachment II was developed byBureau of A1r Management staff at the request of your bureau's Solid WasteSection.

b. Many landfills, especially Superfund sites are filled with manydifferent types of waste, often of unknown nature. Certaincompounds could be emitted fro* such sites that you might notexpect to see at a typical municipal landfill. Should the testingbe for all compounds 1n the Chapter NR 445 tables or just the onesyou would expect to see or have evidence to believe are there?

The guidance referred to in a. above addresses this Issue briefly forlandfills subject to s. NR 506.08(6). The following response addresses thoselandfills not subject to that requirement. I.e., landfills smaller than500,000 cubic yards in capacity. Section NR 445.04 contains four tables ofhazardous air contaminants Identified as Tables 1 through 4. The emissionlimitations established for those contaminants Identified in Table 2 onlyapply to facilities which manufacture or process pesticides, rodenticides,insecticides, herbicides or fungicides. Therefore, Table 2 1s not relevant toa discussion of hazardous air contaminant emissions from landfills.

I agree with your expressed concern that Superfund landfill sites may varywidely, not only with respect to the types and quantities of waste present,but also with respect to knowledge of the site and site design. Because oftheir potential diverse nature, I believe it is appropriate to retain thewidest degree of flexibility with respect to this type of source.As was said earlier, we do not Intend to undertake any special effort tocontact landfill owners concerning the requirements under Chapter NR 445. Ifconcerns are raised, through whatever means, that a site poses potentialhazardous air pollutant emission problems, we will respond to those concernson a case-by-case basis. Testing may be an element of the response to aparticular site. However, a variety of Information may exist to help identitythe air emissions of concern. There may be evidence regarding the volatilityof contaminants or site specific records regarding waste or the types ofindustries which used a site. This type of Information can be used to supportconclusions regarding the presence or absence of contaminants identified inTables 1, 3 and 4. In addition, the presence of a gas extraction system,either passive or active, should be considered when determining the bestmethod to Identify and quantify emissions of hazardous air contaminants.

4. We need clear, up-to-date guidance on proper flare design.

An April 11, 1988 memorandum, identified as Attachment III, presents draftrecommendations for flare design and operating parameters. As you may know,the author of this memorandum has since left the department. We are currentlylooking at this issue for the purpose of finalizing this guidance and will

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keep you updated on any changes made. Note that we have also found that acarbon absorption system met the hazardous air contaminant controlrequirements for landfill gas in a specific case.

If you have additional questions or concerns please contact Pat Kirsop of mystaff.rp'

Lakshmi Sridharan - SW/3

Attachment:

ATTACHMENT I

PROPOSED METHOD FOR ESTIMTINC HAZARDOUS AIRCONTAMINANT EMISSIONS FOB LANDFILLS

STEP 1. In order to dttermine which hmrdous constituents are present 1n aparticular site's gas, monitor Ing wells would be Installed at various pointswithin the landfill. One well would be Installed per five acres of landfill,with a minimum of four wells required. These wells should have long screenscovering all but perhaps the upper 10 or IS feet of the waste In order toobtain average gas concentrations. Unless otherwise determined by the Bureauof Air Management (BAM), each of the wells would then be monitored at leastthree times for all parameters contained 1* Tables I, 3 and 4 of ch. NR 445.Elimination of some of the parameters 1n Tables 1 and 4 may be possible ifthe landfill owner can demonstrate to BAH's satisfaction that their presencein the landfill or possibility of emission Is remote. Only the substancesdetected 1n this step would subsequently be monitored for.

STEP 2. Either during or after performing step 1. above, landfill gasextraction wells would be Installed to the base of the waste. Theseextraction wells would placed at the same frequency as the monitoring wellsmentioned above; one per five acres, or a minimum of four wells. Eachextraction well would be screened over approximately the lower two-thirds ofits length. All extraction wells would be located away from leachatecollection systems or other conduits which could conduct gas or outside airsuch as existing passive system vents. If this Is not possible, sources ofoutside air intrusion must be tightly sealed. Each of the extraction wellswould be connected by flexibe header piping, and the header piping would beconnected to a blower capable of producing a sufficient vacuum within thewaste at all wells. Additional gas monitoring wells would be required atvarious distances from each extraction well in order to determine thedistance from which the extraction well is drawing gas when pumped.

STEP 3. Each quarter, the blower would be run for a period of one or moredays. During this time, the following data would be obtained:

-The gas extraction rate

•The concentration of each substance of concent Identified in step 1.

-The radius of Influence for each extraction well and the volume ofwaste contained within the cylinder formed by that radius

The level of vacuum applied by the blower 1s tot critical. However, itshould not be so great as to cause appreciable outside air Intrusion.

2.

STEP 4. Using the Information gathered In step 3., the owner would berequired to calculate the rate at which each substance of concern is beingemitted in units of pounds per year per cubic yard of waste affected by thetest extraction wells. Then, this data would be extrapolated to estimate thetotal emissions fro* the entire landfill. If, for any quarter of testing,the estimated emission rate for a substance It Table 3 exceeded that allowedin ch. NR 445, installation of an active gas extraction system to efficientlycollect and combust hazardous air contaminants would be required at theearliest possible date. For exceedances of Tables 1 and 4, the landfillowner would have the option of performing air modelling to demonstrate thatambient concentrations at the landfill's property Unt do not exceed ) or24-hour limits. If the standards were not exceeded at the property line, nosystem would be required for hazardous air contaminant control.

For example, assume that from steps 1 through 3 It was determined that forthe second quarter of the third year of testing en a 5,000,000 cubic yardlandfill, the Table 3 parameter vinyl chloride was being emitted at a rate of20 pounds per year, and that the volume of waste affected by the testextraction wells was 200,000 cubic yards. Then, the extrapolation of thisdata would give an estimated emissions rate of 500 pounds of vinyl chlorideper year. Since this exceeds the 300 pound per year level in ch. NR 445, anactive gas system would be required.

If, after five years of quarterly testing, no exceedances of ch. NR 445emission rates had occured, a site would then be exempt from the requirementto Install a system to efficiently collect and combust hazardous aircontaminants.

All questions regarding proper sampling techniques should be addressed toDepartment's Bureau of Air Management.

ATTACHMENT II

STATE OF WISCONSINDepartment of Natural ResourcesBureau of Air Management

Guidelines for the Measurement of HazardousAir Contaminant Emissions from a Landfill.

I. Introduction

So]id waste rules Section NR.504.04 and NR.504.05 of theWisconsin Administrative Code requires municipal solid wastelandfills to collect and combust the landfill gas. The purposeof the rule is the prevention of hazardous emissions into theambient air from the landfill. Solid waste rule SectionNR.506.08 of the Wisconsin Administrative Code allows anexemption, from gas collection and combustion, to existinglandfill if they can show that landfill emissions are below thelimits set down in the air rule Section NR.445. Sampling andanalysis of all volatile organic compounds in landfill gas isrequired. A general approach tc this testing is the measurementof compounds in the landfill gas and the determination of therate at which the gas is exhausted into the ambient air. Fromthe above information it is possible to calculate emission rate-for compounds which can then be cocpared with the emission ra*.*limits set down in the air rule. These guidelines provide sc-eassistance for those who wish tc preform testing for the purposeof obtaining an exemption from requirements to collect andcombust- landfill gas. The guidelines address only the volatileorganic compounds and may not be suitable for hazardoussen-.i.vo]*tile i'b.p. '> 200' Ci compounds. Testing, must be dcr.t- " -•gat wrll that actively extracts gas froKi the landfill andexhaufcts gas. into the air. The well may be permanent or may tt stemporary test well. Three important points that must beaddressed by the testing are:

a. Measurement of gas flow from the well vent (stack'b. Collection of a representative gas sample.c. Analysis of the sample collected.

II. Gas Flow Rate Measurement

A. In order to determine the emission rate of a compoundit is necessary to measure the gas flow rate (GFR) ofthe landfill gas. Gas flow rate can be measured withthe following equipment.

1. Fitot tube2. swinging vane anemcreter3. heated wire anemometer4. heated thermocouple anemometer

The Pitot tube is a primary standard device and as suchis the first choice for making a flow measurement.

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However, the Fitot tube is not capable of makingaccurate measurements below 600 cubic feet per minute(cfm) and for gas wells with GFRs below 600 cfm analternative method must be used. The anemometerslifted above will work at lower flow rates and may besubstituted for the Pitot tube. Anemometers are notprimary standard devices and so must be calibratedagainst a primary standard prior to their use.

B. Messurement of the GFR must take place in an area ofthe stack that has laminar flow (nonturbulent gasflow). To insure sampling in an area of laminar gasflow the location of the sampling port must be at least8 stack diameters downstream of a disturbance and 2diameters upstream. A disturbance is any change in theduct, such as a bend, an expansion or a contraction.

C. The devices listed in part II.A. can not measure the totalflow of gas in a stack. Rather the devices measure flow atsingle points which can be averaged to obtain the gas flowfrom the stack. For stacks (or ducts) of more than 12" indiameter consult Method 1 Appendix A of 40 CFR Part 60 forthe number and locations of sampling points in the stack.For ducts with diameters smaller than 12" the average GFRcsr: be obtained (with an accuracy of •*•/- 5*) by measuringthe gas flow rate in the center of the duct and multiplyingthan value by 0.9.

D. To calculate an emission rate requires the GFR bereported in dry standard cubic feet per minute (DSCFM;.The calculation of GFR ir; DSCFM will requirerce'si-Mremeut of the humility of the landfill gas-.Humidity can be determined by a comparison of thetemperature as measured by a wet bulb and a dry bulbthermometers. If the measurement technique used ismass dependent (as is the Pitot tube) an estimate ofthe gas atomic mass must be made.

III. Sampling landfill gas

A. Sampling train (4 parts)

1. Probe - Designed to extract a gas sample from thecentroid (central) portion of the stack. Theprobe should be made of inert material such asglass or stainless steel.

2. Collection device - see III.B.

3. Gas mover (pump) - If the ptuap is locatedupstream of the collection device it must bedemonstrated that the pump does not affect(add to or reduce) compounds in the sample.

4. Gas meter (flow measuring device) - The metermaintains a constant known sample gas flow.In small sampling pumps this nay be builtinto the pump.

B. Collection devices or media

1. Landfill gas may be collected as a timeintegrated whole gas sample. The whole gassample- may be analyzed directly if themethodology is sufficiently sensitive. Ifsensitivity is insufficient the gas samplemay be preconcentrated prior to analysis.Sampling containers for gas include:

a. tedlar bagb. glass bulbc. stainless steel passivated canisters

The whole gas sampling techniques is good.forhighly volatile compounds. The use ofcryogenic preconcentration of a whole gassample is good for a wide range of volatilecompounds with b.p. ranging from -10 to 200C.

2. Solid or liquid adsorbents may be used tocollect and preconcentrate landfill gassamples. Because no single adsorbent is bestfor all compounds a series of differentadsorbents must be used to capture a widerange of organic compounds. Possible solidpdf-crbents include;

?. TEKAX ieompcund b.p. from 50 to ?00 r-b. carboseives (compound b.p. from -15 to 2C-i"c. silica gel (amines)d. charcoal (organics)

3. Reactive organic compounds (i.e. aldehydes)may deteriorate in a sample before analysis.The collection media should provide somemeans of stabilizing these compounds such a?the formation of chemical derivatives.

IV. Analysis

The sampling media (from II.B.) and the analysis methodm:>st t"r choc sen so that the overall sensitivity of theanalytical method is sufficient to detect compounds ata concentration which would equal or exceed theer.istioti limits set down in Section Nil. 445. As ar.example for the compound benzene the emission limit is3'"j Ibs./year. If the test well discharged 500 cfm oflandfill gas a benzene concentration of 18.3 ug/1 wouldequal the emission limit. Therefore the method chooser;

to sample and quatitate the benzene must be able todetect at least 18.3 ug/1 of benzene in the landfillgas.

B. Chromatography - Analysis of samples will require theuse of gas Chromatography and to a lesser extent liquidChromatography. There is no single analytical methodfor the analysis of all volatile compounds listed inSection NR.445 of the Wisconsin Administrative Code.Testing will require the use of a combination ofseparate analytical procedures to insure that alllisted compounds are within acceptable emission limits.Possible source of information on analysis methodsinclude;

1. EPA/600/4-84/041 Compendium of Methods forthe Determination of Toxic Organic Compoundsin the Ambient Air.

2. National Institute of Occupational Health andSafety (NIOSH) Manual of Analytical Methods

When setting up an analysis method for landfill gastesting the following should be addressed:

1. Sample preparation and introduction into thechromatographic system.

2. Chromatographic condition including thecolumn used and the operation parameter?.

3. Chromatographic detector to be used.4. The limits of detection (LOD) and the limits

of quantitation (LOQ) of the analyticalmethod used.

f . Confirmation procedure used to insure correct,identity of a compound.

V. Ouaiiry Control/Quality AssuranceA quality control program must be established by thoseconducting landfill testing to insure that test resultsare an accurate reflection of the emissions from thegas well. Any QC program established must containelements described in the following section.

A. Gas flow rate measurement

1. Documentation of the methodology to used.2. Calibration of the equipment to be used.

B. Collection of a gas sample

1. Documentation of the sampling methodology.2. Calibration of the gas meter used in the

sample train.3. Collection of sample blanks, spiked samples

and replicate samples.

C. Analysis of samples.

1. Documentation of the analysis methodology.2. Standardization of the chromatographic

system, including the detector if required.3. Analysis of control samples.4. Analysis of available USEPA audit gases.5. Interlaboratory comparison studies.

STATE OF WISCONSIN

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ATTACHMENT III

DATE: April 11, 1988 FILE REF: 4530

TO: Don Theiler. Director - AM/3 |Bureau of Air Management

FROM: Steven Klafka - AM/3

SUBJECT: Draft Design and Operating Requirements for Landfill Gas Flirts

'./Proposed Department rules under Chapter NR 445. His. Ada. Code, would require,,the control of hazardous air pollutants. These were brought before the ^Natural Resources Board on February 24, 1988. Uncontrolled landfttt-gas ventsoften exceed the proposed 300 pound per year criteria level for vinyl chlorideand benzene emissions. This would necessitate the application of lowestAchievable Emission Rate" emission controls, or LAER. In most Instances, aproperly designed and operated shrouded flare 1s expected to providesufficient vinyl chloride and benzene destruction to be considered LAER. Theuse of a gas turbine or reciprocating engine, where feasible, could also beconsidered LAER. Landfills producing gas which would not support combustionwould require a case-by-case LAER determination. This could Include thesinking of additional gas wells to produce a burnable gas and reduce emissionsfrom uncontrolled dilute wells.

Recently I have had discussions with Department solid waste management staffand landfill designers concerning-the LAER design and operating requirementsfor flares burning landfill gas. Attached are my preliminary recommendationsfor the requirements we should adopt for those landfills exceeding the LAERcriteria levels for vinyl chloride or benzene in the proposed hazardous airpollutant rules. These are based on my discussions with the South Coast AirQuality Management District in California. Under their rule 1150.1, landfillsare required to install and test landfill gas control systems, both for airtoxics and ozone control. These requirements emphasize the design, operationand testing of the flare. No minimum destruction efficiencies are specified.

SK:lm/4574EAttach.

cc: 0. Rlckun - AM/30. Packard • AM/3J. Chazln - AM/3P. Didier - SH/3

Landfill Gas Flare

Drift Design and Operating Requirements

Under Proposed Chapter 445, W1s. Adm. Code

Flare type -

Operating temperature -

Combustion air control

Temperature monitoring

Emissions testing -

Shrouded flare without visible flame*

1400°F for 0.3 seconds after flare burner(Hazardous waste landfills may require longerresidence times.)

Varied 1n order to maintain operating temperature.

Continuous measurement and recording of flue gastemperature after the flame zone, and lowtemperature/flame out telephone alarm system tonotify responsible party. Quarterly reports.

A series of four quarterly tests under normaloperating conditions, at the Inlet and outlet ofthe flare, for the concentration and massemission rate of carbon monoxide, carbon dioxide,methane, total nonmethane hydrocarbons, and LAERpollutants (i.e. vinyl chloride and benzene).Low exit velocities may require that the outletflow rate be calculated rather than measured.Determine destruction efficiency for methane,nonmethane hydrocarbons, and LAER pollutant(s).

March 1988.4574E

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