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Municipal Solid Waste (MSW) Landfill MACT Summary


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4. What do the Standards Require?

FlareMajor and area source landfills with a design capacity of greater than or equal to 2.5 million Mg and 2.5 million m3, and with estimated uncontrolled NMOC emissions of at least 50 Mg/yr, would continue to be subject to the EG/NSPS as applicable, plus additional requirements imposed by the final rule. These requirements also apply to bioreactors within active landfills at both major and area sources if the landfill meets the design capacity criteria. Sources are required to meet the Startup Shutdown and Malfunction (SSM) [PDF] requirements that are listed in the general provisions to 40 CFR part 63.

The source must develop and implement a written SSM plan that describes in detail the procedures for operating and maintaining the collection and control system and the continuous monitoring system (CMS) during periods of SSM. There are also recordkeeping and reporting requirements for SSM incidents.

The final rule also requires the source to operate the control device within the operating parameter boundaries and to continuously monitor control device operating parameters. Compliance with the operating conditions is demonstrated when monitoring data show that the gas control devices are operated within the established operating parameter range. Compliance also occurs when data quality is sufficient to constitute a valid hour of data in a 3-hour block period. Deviations occur when a source's 3-hour average falls outside the established boundaries. A deviation also occurs when more than 1 hour in a 3-hour average is considered invalid.

To be considered a valid hour, measured values must be available for at least three 15-minute periods within the hour. If such a deviation occurs, then the source may be in violation of operating conditions (that is, in violation of proper operation and maintenance of a control device).

Inspection Landfill Gas Collection SystemWith one exception, the final rule also requires you to submit the reports that are specified in the EG/NSPS control requirements, or in the Federal plan, the EPA-approved State plan, or Tribal plan that implements standards for new sources, whichever is applicable. As an exception, the report required in section 40 CFR 60.757(f) must be submitted every 6 months rather than annually. The report pertains to the control device operating parameter value and the duration of time that control devices were operating in out-of-bounds conditions, the duration of periods when the landfill gas stream was diverted from the control device(s), the location of areas that exceed the 500 parts per million methane concentration limit, and the dates of installation and location of each added well or collection system expansion.

If a landfill is subject to the final rule because it is placed with with a major source and the landfill has a design capacity less than 2.5 million Mg or 2.5 million m3, the landfill must comply with the applicable EG/NSPS requirements (i.e., it must submit a design capacity report). The landfill would not be subject to additional control and reporting requirements under the NESHAP. Note that while area source landfills that have a design capacity less than 2.5 million Mg or 2.5 million m3, or estimated uncontrolled NMOC emissions less than 50 Mg/yr (for landfills other than bioreactors) are not subject to the final rule, they must continue to comply with the provisions of the NSPS or State, tribal, or Federal plan that implements the EG, as applicable.

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