The US EPA is proposing amendments to the landfill NESHAP. Based on the results of the required Residual Risk and Technology Review, the EPA is proposing changes to the Start-up, Shutdown, and Malfunction (SSM) language, as well as requiring electronic submission of compliance reports and performance tests.
The proposal also includes clarifications to the 2016 NSPS (Subpart XXX) and EG (Subpart Cf) regarding NESHAP compliance; specifically, a landfill can demonstrate compliance with the “major compliance provisions” of the revised landfill NESHAP in lieu of NSPS and EG.
The rule proposes changes to wellhead operational standards. Maintaining consistency with the NSPS and EG, the specific operational limits for oxygen or nitrogen content have been removed, although monitoring and recordkeeping are still required. Additionally, the proposed standards have increased the temperature standard from 131 degrees to 145 degrees, although the increased limit comes with increased monitoring and reporting requirements for any wells that exceed the new limit. In particular, if a well that exceeds 170 degrees, and a CO reading of >1,500 ppm, the facility will be required to notify the delegated agency about the well. While it is still possible to request a higher operating value (HOV) for any well that exceeds the new standard, the landfill NESHAP contains very specific requirements regarding the data required for the demonstration, and the enhanced monitoring to be performed while waiting for the approval.
Tier 4 has been removed from the list of acceptable NMOC calculation procedures.
The full text of the proposal can be found here.
Comments on this proposal are due September 12, 2019. SWANA is working with NWRA and some private stakeholders to prepare comments.
We will continue to follow this issue as it develops. Please reach out if you have a particular interest in this issue.
Please contact the Hoosier Chapter to provide comments or questions.