Richardson Smith Gardner and Associates

Lori Ann Phillips, P.E. joins Richardson Smith Gardner and Associates, Inc.

2011-11-22T15:16:00.012-05:00

New hire grows RSG’s expertise in air quality and landfill gas services.

RALEIGH, NC -- An engineer with diverse air quality compliance experience has joined Raleigh-based solid waste engineering and consulting firm Richardson Smith Gardner & Associates, Inc. (RSG).

Lori Ann Phillips, P.E., who has managed environmental and air quality issues for public and private facilities, has been named Project Engineer at RSG, which is celebrating its 20th anniversary this year.

Ms. Phillips is the latest hire to help further RSG’s commitment to the development and application of innovative technologies in the area of solid waste management. Ms. Phillips will be a key member of a team that will advise clients about permitting and compliance issues related to air emissions.

“We are pleased to offer the talents of an engineer such as Lori to our clients seeking practical, cost-effective solutions that address the typically sensitive issues surrounding air emissions,” said RSG President, Stacey Smith, P.E. “Her extensive, previous experience in dealing with these issues will help us tailor solutions that can substantially reduce the impact of landfill gases for our client base.”

Ms. Phillips most recently was a permit engineer for the N.C. Department of Environment and Natural Resources, reviewing air permit applications for the department’s Division of Air Quality. Previous experiences in similar roles with Arcadis and with Progress Energy, as well as a research role at N.C. State University, round out Ms. Phillips impressive resume.

“I look forward to preparing our clients to face the myriad issues associated with air quality compliance and permitting,” said Ms. Phillips. “I am excited about joining the RSG team, and being a part of RSG’s commitment to innovative approaches to solid waste solutions.”

Ms. Phillips’ commitment to air quality began while still an engineering student at Wilkes University, where she was student chapter president of the Air and Waste Management Association, an organization in which she is still active. She also holds a Masters Degree in Civil Engineering from N.C. State and recently earned her Professional Engineer’s license.

For More Information Contact:

Mr. Stacey A. Smith, P.E.
President
Richardson Smith Gardner & Associates, Inc.
http://www.rsgengineers.com/
(919) 828-0577, ext. 127
stacey@rsgengineers.com

Financial Assurance for Corrective Action at Landfills - House Bill 209

2011-05-27T14:22:00.002-04:00

On March 1, 2011, House Bill 209 (HB 209) was introduced by primary sponsors, Representatives Dan Ingle (District 64 – Alamance County) and Mitch Gillespie (District 85 – Burke and McDowell Counties). The proposed bill, if adopted, will amend certain financial assurance requirements for sanitary landfills sanctioned by Session Law 2007-550 (Senate Bill 1492).

As ratified, SB 1492 placed additional requirements for new and existing landfill facilities. One of these requirements directed the owners or operators of sanitary landfills to establish financial assurance in the amount of three million dollars (minimum) to cover the potential assessment and corrective action costs. Local governments and solid waste authorities could fulfill this prerequisite by satisfying the local government financial tests or by committing a capital reserve fund. However, this legislation did not provide any alternatives for privately held facilities to comply with this financial obligation.

As currently transcribed, HB 209 proposes to reduce the financial assurance obligation to two million dollars and sets forth provisions to allow the owners and operators of landfills permitted on or before August 1, 2009 means to satisfy the financial assurance commitment through the development of a trust fund under the following provisions:

• The trustee shall be an entity which has the authority to act as a trustee and trust operations are regulated and examined by a State or Federal agency;

• A copy of the trust agreement shall be placed in the facility’s operating records;

• Payment into the trust fund shall be made annually by the owner or operator over a period not to exceed five years;

• Payment into the fund shall be made in equal annual installment amounts;

• The trust fund may be terminated by the owner or operator only of the owner or operator establishes financial assurances by another means; and

• The trust agreement shall be accompanied by formal certification of acknowledgement

HB 209 passed the first reading in the House on March 3, 2011 and was referred to the House Committee on the Environment which met to discuss the merits of the provisions on May 26, 2011. The bill was passed by the committee and will move on to the floor.

The General Assembly’s 2011 regular session’s cross over date is June 9, 2011. If the provisions of HB 209 are to be enacted, a companion bill in the Senate may need to be introduced and all actions or modifications adjusted by any of the reviewing legislative committees have to be approved by both houses of the General Assembly prior to ratification.

A copy of House Bill 2009 can be found at: http://www.ncga.state.nc.us/Sessions/2011/Bills/House/HTML/H209v1.html

The primary sponsors of the bill may be reached at the following contact information:

Rep. Dan Ingle
Dan.Ingle@ncleg.net
(919) 733-5905

Rep. Mitch Gillespie
Mitch.Gillespie@ncleg.net
(919) 733-5862

RSG will continue to monitor this important legislation and will provide updates as appropriate.

EPA Extends the Deadline for 2010 Greenhouse Gas Emissions Reporting

2011-03-01T14:49:00.003-05:00

In a press release issued earlier today, EPA has announced that it is extending the deadline for reporting of 2010 Greenhouse Gas (GHG) emissions under 40 CFR Part 98 beyond the original due date of March 31, 2011. This extension will provide EPA with sufficient time to develop and implement the electronic Greenhouse Gas Reporting Tool (e-GGRT), which is required to report emissions. Originally scheduled for release in late February or early March, the press release now states that EPA “plans to have the final electronic reporting tool available in late summer”. No revised reporting deadline was given, although it will presumably follow the release of the reporting tool, in late summer or early fall of 2011.

The entire press release and associated information is available from the EPA at http://www.epa.gov/climatechange/emissions/extension.html.

Jeri Covington joins Richardson Smith Gardner and Associates, Inc.

2011-01-20T11:02:00.010-05:00

New hire bolsters RSG’s expertise in reducing the cost of solid waste management for municipalities

RALEIGH, N.C. – (January 18, 2011) - The solid waste engineering and consulting firm Richardson Smith Gardner & Associates, Inc. (RSG) has hired Jeryl Covington, P.E., the 11-year director of environmental services for the City of Greensboro, North Carolina.

RSG has been lowering solid waste disposal costs by developing and applying innovating technologies since it started in 1991. Now with the addition of Covington, the company says it can advise municipalities and companies about improvements to the business side of solid waste operations. “Because of her role in Greensboro, Jeri has dealt with as many challenges as anyone in the state,” says RSG President Stacey Smith, P.E. “She brings knowledge of day-to-day operations that we can’t necessarily see as “outside” engineers. This improves our ability to offer solutions that help solid waste groups accomplish their goals.”

As a project manager at RSG, Covington will help organizations optimize their waste management programs by evaluating waste streams and costs. “I empathize with clients and will target the development of strategies and products that are really useful and efficient and meet their budget needs,” says Covington

During her tenure with the City of Greensboro, she oversaw everything from budgets and environmental compliance to site selection for a new landfill/transfer station and trash collection from more than 65,000 households. Covington says, “I’ve been in the operator’s seat. I’ve looked at budgets. I’ve looked at duct-taped equipment. I can help clients figure out how to make it all work."

Covington has worked in the public and private sector since she graduated from North Carolina State University with a degree in civil engineering.

Covington is passionate about supporting the industry, lending her leadership and knowledge to a wide range of organizations. She’s on the board of directors for the Solid Waste Association of North America, serving as chapter president in 2007 and 2009. She’s also on the board of the Sustainability Council’s Public Technologies Institute. Smith says, “We’re pleased to be able expand our services by hiring Jeri, because she has such a strong reputation among her peers as well as state agencies.

In the past she’s served on the board of the National Association of Local Government Environmental Professionals, American Society of Civil Engineers, the Engineering Technology Advisory Board for Guilford Technical Community College and the board of the Communities in School of Greensboro.

For More Information Contact:

Mr. Stacey A. Smith, P.E.
President, RSG
(919) 828-0577, ext. 127
stacey@rsgengineers.com

GHG Permitting for Landfills put on Hold

2011-01-12T16:14:00.000-05:00

According to a press release issued by the U.S. EPA on January 12, 2011, EPA is deferring greenhouse gas (GHG) permitting requirements for carbon dioxide (CO2) emissions from biomass-fired and other biogenic sources, including landfills. EPA plans to complete a rulemaking in July 2011 that will defer permitting of CO2 emissions from these sources for three years. During this time, EPA will consider the more than 7,000 comments received during July 2010, including whether burning of biomass results in a net increase in CO2 emissions.

EPA also plans to issue guidance to state and local permitting agencies that, during the three-year deferral period, the use of biomass as fuel, including landfill gas, constitutes Best Available Control Technology for GHG emissions.

Setting Government Straight Public Comment Period

2010-10-28T15:33:00.000-04:00

Governor Perdue seeking feedback from counties on regulatory reform

Governor Beverly Perdue has initiated a Regulatory Review process aimed at reviewing the thousands of government regulations and rules that have been implemented by various state agencies and regulatory commissions. At a press conference Thursday in Chatham County, Governor Perdue announced her Setting Government Straight initiative and invited the comments of NCACC First Vice President Kenneth Edge of Cumberland County and Chatham County Commissioner George Lucier to give the county perspective.

Governor Perdue is specifically seeking feedback from counties about any rules, regulations and requirements that do not make common sense. As part of this process, the Governor has instructed all of her cabinet agencies to stop creating new rules unless they are absolutely necessary and justifiable, until a thorough review can be completed.

Governor Perdue wants to hear from you about specific examples of how state government and local government intersect in areas such as the departments of Environment and Natural Resources, Commerce, Health and Human Services, and Transportation. The governor’s team is looking for specific examples of how these interactions can be streamlined for better efficiency and cost-savings.

Governor Perdue has created a Web site to solicit feedback. This is a great opportunity for our counties to highlight some real-world examples of redundant and ineffective state regulations that impede county service delivery. The website address for comment is:
http://www.governor.state.nc.us/forms/setGovernmentStraight.aspx/

Proposed Solid Waste Management Rule Changes

2010-09-24T09:52:00.001-04:00

NCDENR has released proposed rule changes for North Carolina solid waste facilities. These rule changes address several points which include:

• The disposal of untreated wood at Land Clearing and Inert Debris (LCID) facilities (15A NCAC 13B.0101 & 0563);
• Clarification of critical language regarding leachate releases (15A NCAC 13B.1604 & .1626); and
• Removal of the requirement to perform statistical analysis on groundwater monitoring data (15A NCAC 13B.1632 - .1635, & .1637).

The proposed rule changes can be viewed in full at the following:

http://www.oah.state.nc.us/rules/register/Volume25Issue4August162010.pdf

The comment period for these proposed rule changes ends on October 15th. Comments can be sent to:

Ellen Lorschieder
NCDENR – Division of Waste Mgt – Solid Waste Section
Planning and Programs Branch Head
1646 Mail Service Center
Raleigh, NC 27699-1646

E-mail: Ellen.lorscheider@ncdenr.gov
Phone (919) 508-8400

A brief summary of the proposed changes and their potential impact to landfills in NC is provided below.

Untreated Wood in LCID Landfills -15A NCAC 13B.0101, & .0563

The proposed rule changes remove untreated wood as a waste that can be accepted at LCID landfills. This proposed rule change is explained by NCDENR as being necessary due to the numerous markets for recycling untreated wood. The reason for the proposed rule change further states that since most untreated wood is comingled with treated wood, paint and other construction and demolition debris, this waste can become contaminated by these other wastes and thus may pose an environmental threat due to the origin of generation.

Potential Impact to Solid Waste Facilities

Untreated wood will no longer be accepted at LCID facilities and must either go to a C&D facility or be recycled at the source.

Leachate Release Definition – 15A NCAC 13B.1604 & .1626

The proposed rule change changes the definition of a leachate release from “from the permitted facility” to “outside the liner, collection system or other containment component”. This defines a leachate release as any release that migrates beyond the liner or leachate collection system (effectively anywhere outside the landfill anchor trench). NCDENR provides the reason that this rule change is proposed is to eliminate ambiguous wording, and to prevent any leachate release from outside the landfill liner system due to a potential for environmental impact.

Potential Impact to Solid Waste Facilities

Any leachate seep or release of leachate that is discovered outside the leachate collection system of the landfill will be against the law and the site will be subject to Notice of Violation and potential fines.

Removal of Statistical Analysis Requirement – 15A NCAC 13B.1632 - .1635 & .1637

This proposed rule change removes the requirement for statistical analysis of groundwater monitoring data and relies solely upon groundwater standards (15A NCAC 2L.0200) and Interim Maximum Allowable Concentrations (IMACs) for a determination if groundwater has been impacted by a facility. This is proposed due to the redundancy of the statistical analysis with the groundwater standards that NC already had in place at the time of adoption of Subtitle-D.

Additionally, the proposed rule changes include a revision to the section regarding completion of groundwater remediation. Previously, this section outlined that compliance with groundwater standards after a remedial action could be achieved through statistical analysis indicating no statistical increases over a period of three years. The proposed change removes the statistical analysis requirement and indicates that compliance may be achieved through no exceedance of groundwater protection standards over three years.

Potential Impact to Solid Waste Facilities

The good news is that this will potentially reduce regular groundwater monitoring costs for landfills where statistical analyses are currently required (MSW landfills). For naturally occurring constituents, some landfills may want to continue using statistical analysis in order to show that the naturally occurring concentrations are not increasing due to impact from the landfill.

The bad news is that removal of the guidance for statistical analysis may unintentionally create more confusion about how statistical analysis should be performed. Additionally, clarification regarding whether additional Alternate Source Demonstrations will be required for naturally occurrring constituents is needed. If additional ASD reports will be required, any savings by limiting statistical analysis will be lost in the generation of these additional reports.

If you have any questions as to how these rule changes may affect your particular facility, please e-mail Joan Smyth, P.G. (Joan@RSGengineers.com) or Pieter Scheer, P.E. (Pieter@RSGengineers.com) or phone: (919) 828-0577.

DWQ Revised Interim Maximum Allowable Concentrations

2010-09-21T10:26:00.003-04:00

The Division of Water Quality (DWQ) established revised Interim Maximum Allowable Concentrations (IMACs) as a part of the most recent triennial review. Some of these IMACs went into effect on August 1st, while others go into effect on October 1st 2010. These revised IMACs could affect how the results of fall groundwater monitoring events are evaluated this year, and going forward. The revised IMACs are as follows:

All these standards are either new, or lower than previous standards. The inorganic (metal) constituents will likely cause the most new detections above groundwater standards as these can be naturally occurring at higher concentrations than those listed as IMACs.

Please contact Joan Smyth, P.G. at 919-828-0577 x 221 or by email at joan@rsgengineers.com for further information regarding how these new standards may affect your groundwater monitoring.

Frank Terry Joins Richardson Smith Gardner & Associates

2010-07-15T23:24:00.000-04:00

Frank Terry Joins Richardson Smith Gardner & Associates
RALEIGH, N.C. - Richardson Smith Gardner & Associates, Inc. (RSG) announced the addition of Frank Terry to the firm.

Frank joins the firm as Project Manager (Landfill Gas), and will be responsible for leading the RSG Landfill Gas Operations Team.

Frank brings 10 years of experience managing landfill gas-to-energy well field operations.

Prior to joining RSG, Frank worked for DTE Biomass Energy as Gas Production Manager, responsible for well field optimization and compliance.

"We are excited about Frank joining our team," said Stacey Smith, company president. "He brings a level of professionalism, experience and expertise that will allow our firm to better serve our current clients, and expand our services to new clients."

About RSG: RSG is one of the nation's leading firms in the solid waste consulting industry. Founded in 1991, this regional consulting engineering firm's business philosophy is simple - to lower solid waste disposal costs through development and application of innovative technologies. Today, RSG's collective experience of engineers and scientists has earned a reputation that rivals or exceeds that of many larger national firms. For more information, visit www.rsgengineers.com.

Summary of EPA’s Technical Corrections to the Mandatory Greenhouse Gas Reporting Rule

2010-06-02T13:04:00.000-04:00

On May 27, 2010, the Administrator signed a proposed rule that includes technical corrections, clarifications, and other amendments to the Greenhouse Gas Mandatory Reporting rule (MRR), which was published on October 30, 2009 (40 CFR part 98). Several of the proposed changes would affect how greenhouse gases (GHGs) are reported from landfills under Subpart HH of the Rule. Briefly, these changes include:

Clarification of the definition of a landfill gas (LFG) collection system to exclude passive vents and flares;
Specific exclusion of hazardous waste, C&D, and industrial landfills from the Rule;
Clarification of how undocumented historical waste disposal amounts are to be calculated;
Clarification of how current and future waste acceptance rates are to be calculated;
Revision to how LFG generation is to be calculated;
Clarification of how LFG parameters are to be measured; and
How leachate recirculation is to be considered along with average annual rainfall when determining k values.

Public comments to these changes must be received by EPA by July 11, 2010. A public

hearing must be requested by June 3, 2010. More information may be found at the EPA’s

web site at: http://www.epa.gov/climatechange/emissions/technical-corrections.html.

RSG will continue to monitor the EPA web site for final passage of these proposed changes.

§98.6 clarifies the definition of a “gas collection system or landfill gas collection system” as a system of pipes used to collect landfill gas from different locations in the landfill by means of a fan or similar mechanical draft equipment to a single location for treatment (thermal destruction) or use. This definition specifically excludes “passive” systems.

§98.340(b) specifically excludes Subtitle C or TSCA hazardous waste landfills, dedicated construction and demolition (C&D) waste landfills, and industrial waste landfills.

§98.343(a)(1) clarifies the method for calculating annual modeled methane generation using Equation HH-1. The start year is revised to be 1960 (if the actual start years is unknown), instead of 50 years prior to the year of emissions estimates, as previously stated.

§98.343(a)(3) specifies how annual quantities of waste disposed in the landfill are to be calculated. (a)(3)(i)(A) specifies that direct measurements of each load be made by weighing each vehicle or container as it enters the landfill, and again after it has off-loaded the waste. Alternately, (a)(3)(i)(B) allows for vehicle tare weights to be used in lieu of measuring the “outbound” weight of the vehicle or container. At least five (5) of each vehicle or container types must be weighed after off-loading to establish a representative tare weight.

EPA originally assumed that all MSW landfills were equipped with scales, however, several commenters to the final rule indicated that is not the case. Additionally, although EPA intended that disposed waste quantities be determined by direct scale measurements, the rule may be interpreted to allow other methods. Therefore, EPA revised (a)(3)(ii) to allow for the mass capacity of each vehicle or container type to be determined by volume and density measurements, and recording the number of each vehicle or container type. The annual waste disposal amount is then determined by multiplying the number of vehicles or container types by their mass capacity. Density may be determined for different vehicle or container types with portable wheel or axle scales.

Several significant changes are made to Table HH-1 – Emission Factors, Oxidation Factors, and Methods, as follows:

Regarding waste modeling, k value determination has been changed so that, in addition to average annual rainfall, leachate recirculation, in inches per year, must also be considered. Annual inches of leachate recirculation is to be determined by dividing the total volume of leachate recirculated by the area of the portion of the landfill (presumably receiving recirculated leachate), with appropriate conversion factors.

The parameter for L_o is replaced by DOC (bulk waste), with a default value of 0.20.

DOC and k values of 0 are also assigned for inerts (e.g., glass, plastics, metal, and cement).

Changes to Table HH-2 - U.S. Per Capita Waste Disposal Rates are made for years 1989 through 2009.

Changes to Table HH-3 – Landfill Gas Collection Efficiencies are made to differentiate between final soil covers with a minimum of three (3) feet thickness of clay and/or geomembrane, and those with less than three (3) feet of clay and no geomembrane.

Additionally, several minor revisions and clarifications have been made, as follows:

§98.343(a)(4) specifies that historical waste disposal quantities should only be determined once.

§98.343(b)(1), Equation HH-4 is revised to delete the conversion factor for minutes per day (1,440), and compensates for this change by redefining (V)_n as cumulative instead of daily volumetric flow. Equation HH-4 also specifies how volumetric flow is to be corrected for moisture (if needed) by replacing the term [1-(f_H2O)_n] with (K_MC).

Throughout §98.343 (b), including Equation HH-4, measurement periods are defined for methane concentration, temperature, pressure, and, if needed, moisture content as occurring once each calendar week, with at least three (3) days between measurements.

§98.346(a) specifies how leachate recirculation during the previous 10 years is to be reported.

§98.346(b) specifies how historical waste disposal data are to be reported.

§98.346(f) requires reporting of specific cover (i.e., organic, clay, sand, or other) types used, and the surface areas of each.

§98.346(h & i) requires an indication of whether passive vents and/or passive flares (as defined in §98.6) are present.

§98.346(i) requires reporting of total annual LFG flow collected for destruction, average annual methane concentrations, monthly average LFG temperature and pressure (if not incorporated into internal calculations run by the monitoring equipment), and monthly average LFG moisture content (if needed).

EPA Finalizes Greenhouse Gas Tailoring Rule

2010-05-22T07:51:00.002-04:00

On May 13, 2010, the U.S. Environmental Protection Agency (EPA) issued a final rule that regulates greenhouse gas (GHG) emissions from stationary sources under the Clean Air Act (CAA) permitting programs. The rule is “tailored” to raise the emission threshold for major sources of GHGs above the thresholds for other pollutants. Currently, sources of criteria pollutants with emissions exceeding 100 and 250 tons per year are subject to Title V and New Source Review Prevention of Significant Deterioration (PSD) permitting, and are required to install Best Available Control Technologies (BACT).

The GHG tailoring rule will be implemented in 3 steps over the next two (2) years and will require control of GHGs from sources emitting 75,000 to 100,000 tons of carbon dioxide equivalent (CO2e) per year (TPY). EPA is also evaluating the expansion of this rule to include smaller sources emitting 50,000 TPY. The majority of newly permitted sources will be solid waste landfills and industrial facilities.

For comparison purposes, using EPA’s LandGEM emission calculation tool, the 75,000 to 100,000 TPY thresholds equate to:

• Landfill gas (LFG) emission rates ranging from approximately 670 to 875 cubic feet per minute (cfm) at 50% methane
• MSW landfills accepting 150,000 tons per year or more over a 9 to 12-year period

BACT for landfills is presumed to be gas collection and control systems. As a result, this rule will mandate the installation of active LFG collection and control systems at facilities well under the current NSPS thresholds , and possibly make these facilities ineligible to claim carbon credits for the voluntary destruction of methane.

Implementation

Step 1 of the rule will be implemented from January 2, 2011 through June 30, 2011, and will regulate sources currently subject to the PSD permitting program due to emissions of non-GHG pollutants. Increases in emissions of GHGs of 75,000 TPY or more would trigger determination of the BACT for their emissions, and modification of the Title V operating permit to reflect the increase in emissions.

Step 2 would be implemented no later than July 1, 2012, and would on require Title V permitting for sources emitting 100,000 TPY or more of GHGs, and impose PSD permitting requirements and BACT existing sources with modifications that increase GHG emissions by 75,000 TPY or more.

Step 3 will occur from the beginning of 2011 to July 1, 2012, and consists of additional rulemaking by EPA to determine whether smaller sources should be included or excluded from permitting. If established, this additional permitting may apply to sources with GHG emissions as low as 50,000 TPY. If additional rulemaking is finalized, it would not require additional permitting of smaller sources until April 30, 2016.

Further information on the tailoring rule may be downloaded from the EPA web site at: http://www.epa.gov/nsr/actions.html#2010 . Additionally, you may contact me at (919) 828-0577 ext. 121 or matt@rsgengineers.com , or log on to our blog at www.rsgengineers.com/blog with any questions.

Greenhouse Gas Reporting Rule Summary

2009-12-18T14:39:00.000-05:00

On September 22, 2009, the U.S. Environmental Protection Agency (EPA) issued a final rule for mandatory reporting of greenhouse gases (GHGs) from large GHG emissions sources in the United States, including certain municipal solid waste (MSW) landfills. According to the rule, sources that generate GHGs exceeding 25,000 metric tons of carbon dioxide equivalent (tCO2e) must monitor and report these emissions to EPA. For comparison, a typical affected landfill may have:

• landfill gas (LFG) flow rates approx. 240 cubic feet per minute (cfm) at 50% methane, and
• waste acceptance of 50,000 tons per year or more of waste over a 15-year period.

Facilities with MSW landfills that accepted waste on or after January 1, 1980 and generate methane (CH4) in amounts equivalent to 25,000 tCO2e or more per year are subject to the rule. The 25,000 tCO2e threshold is based on the amount of CH4 generated from a facility’s landfill(s) (adjusted for soil oxidation, but not considering whether any gas is collected and destroyed) and not the amount of CH4 actually emitted. If a single facility contains multiple landfills, then the sum of each landfill’s generated CH4 emissions must be used to determine if the facility exceeds the 25,000 tCO2e per year threshold for reporting. Emissions monitoring requirements begin January 1, 2010, with the first reports due March 31, 2011.

A landfill subject to the rule must report its “actual” CH4 emissions. For landfills with no collection system, actual emissions equal generated emissions. For landfills that do collect and destroy LFG, methane destroyed in flares, engines, or other devices is deducted to determine actual emissions. As a result, these facilities must monitor the following:

1. Gas flow rate;
2. CH4 concentration;
3. Gas temperature; and
4. Gas pressure.

With the exception of gas flow rate, these parameters must be recorded at a minimum frequency of once per week. Flow rate must be monitored continuously.

Note: Per EPA’s response to our inquiry, passive vent flares do not constitute “collection and control”, and are therefore not required to be monitored for the above parameters. These flares are to be ignored for reporting purposes.
Landfills without collection and control systems are required to record incoming MSW and biosolids waste streams separately, at a minimum.

Deadlines:

January 1, 2010 – Begin recording data for reporting
January 28, 2010 – Submit requests for extension of use of best available monitoring methods beyond March 31, 2010
March 31, 2010 – Implement monitoring and meter calibration practices required by rule, and discontinue best available monitoring methods
December 31, 2010 – Complete 2010 data generation
January 30, 2011 – Submit certificate of representation to EPA, designating person(s) responsible for report submittal (NOTE: Outside consultants may be designated).
March 31, 2011 – Submit GHG report for 2010
ONGOING – Submit corrected report within 45 days of discovery of reporting error(s).

Further information on the rule can be found at the following link: http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.

“Industrial” landfills are not required to report 2010 emissions, HOWEVER; EPA anticipates reporting will be required in 2011. Construction and demolition landfills may be included in this category.

In addition to this final rule, EPA has also proposed a rule for the mandatory control of GHG emissions from MSW landfills with the potential to emit 25,000 tCO2e or more per year. This rule is in the public comment period, which ends December 27, 2009.

Please feel free to contact RSG at (919) 828-0577 ext 121 or matt@rsgengineers.com with any questions related to either of these proposed or final rules.

Revised Groundwater Standards Effective January 1st 2010

2009-10-19T13:53:00.018-04:00

North Carolina’s Division of Water Quality has been performing a triennial review of groundwater standards (15A NCAC 2L.0200). Based upon their review, the DWQ proposed several changes that included lowering 15 existing standards to make them more stringent, increasing 12 standards to make them less stringent and finally to remove 12 standards altogether. An initial summary of the proposed changes was presented at the NC SWANA conference in April 2009 and can be found on our website through this link.

The Environmental Management Commission (EMC) has reviewed the proposed revisions to the standards and ruled on them. In some cases, the EMC revised the limits proposed by the DWQ. The standards as revised and adopted by the EMC will become effective January 1st, 2010.

Several of the revisions are helpful to the solid waste industry, including the provision to keep the 12 standards that were proposed for removal. However, some of the reduced standards are included in the semi-annual monitoring for landfill facilities which could cause problems for some landfill facilities. Of the revised (lowered) standards, Arsenic, Barium, Chromium, 1,1 Dichloroethane and Toluene are likely to cause issues for landfills in North Carolina with additional detections of these constituents above the new groundwater standards. If you have any questions as to how these new standards will affect your facility, please call Joan Smyth of RSG at 919-828-0577 x 122.

The existing standards, the DWQ proposed standard and the final (EMC Adopted) standard that will take effect January 1st are summarized below.

New Edge-of-Waste Marker Requirements in NC

2009-10-15T11:38:00.003-04:00

The Solid Waste Section (SWS) of the North Carolina Department of Environment and Natural Resources has recently issued a memorandum (http://www.wastenotnc.org/swhome/
NewsPostings/Property_Line_Waste_Markers_Memo_052909.pdf) stating that landfill owners are required to install and maintain permanent edge-of-waste markers for all landfill units by January 1, 2010.
For newer lined landfill units that do not already have markers in place (typically for edge-of-liner) this is a relatively straight-forward requirement since an as-built survey of the edge of the landfill liner is typically available. However, for some older unlined landfill units, the edge of waste can be difficult to determine without the performance of some investigation. The SWS has found sites where waste is not within permitted areas, within buffers, and in a few case not within the property line. Thus, they are placing a priority on knowing where these waste limits exist.
It is our opinion, that the SWS’s ultimate goal of this effort is to both have visual field markers and an accurate public record that waste exists within the property. We have seen several cases where these older landfills were purchased unknowingly by landowners that in some cases proceeded to locate residential developments over these areas. Therefore, the reaction of the DENR has been to supplement this information to help further safegaurd the public at-large.
We are aware that this effort results in unexpected costs for the owner. For sites where the edge of waste is not clearly known, investigative techniques to determine this limit can include a review of available drawings; performance of test pits or borings; and/or performance of a non-intrusive geophysical survey. Additionally, in the case of older sites, a survey of the determined limits of waste would accompany a deed recording for future reference.

The section has also published a follow up memo to provide more insight into the background of there decision to require these markers. A copy can be found at http://www.wastenotnc.org/swhome/NewsPostings/EOWMarkerMemo.pdf

RSG would welcome the opportunity to meet with you to discuss how we can help you meet this new compliance requirement. Please contact Mrs. Joan Smyth, P.G. for any questions at joan@rsgengineers.com.

Proposed Mandatory Greenhouse Gas Permitting and Control

2009-10-14T17:19:00.000-04:00

On September 30, 2009, EPA proposed to regulate large facilities, including municipal solid waste (MSW) landfills, emitting over 25,000 metric tonnes carbon dioxide equivalent (tCO2e) of greenhouse gases (GHG) a year. For comparison, using EPA’s LandGEM emission calculation tool, this equates to:

· Landfill gas (LFG) emission rate of 240 cubic feet per minute (cfm) at 50% methane
· MSW landfills accepting 50,000 tons per year or more over a 15-year period

According to the EPA, the majority of sources newly affected by this proposed rule are expected to be municipal solid waste landfills. As shown above, small to medium sized landfills would be affected, relative to current NSPS rules.

Facilities emitting 25,000 tCO2e would be considered major stationary sources required to be permitted under the Prevention of Significant Deterioration (PSD) air program. Additionally, existing major sources making modifications that result in an increase of emissions above the significance level of 10,000 tCO2e would be required to obtain a PSD permit. EPA will evaluate this rule after five years, and determine if these thresholds should be adjusted, presumably downward.

These operating permits would likely require best available control technologies and energy efficiency measures to minimize GHG emissions. These controls are determined on a case-by-case basis during the PSD process, and may include open or enclosed flares, reciprocating engines, or boilers.

This proposed rule could mandate the installation of active LFG collection and control systems at facilities well under the current NSPS thresholds of 50 Megagrams (Mg) per year, and possibly make these facilities ineligible to claim carbon credits for the voluntary destruction of methane.

EPA will accept comment on this proposal for 60 days following publication in the Federal Register.

For information on submitting comments, or to download the proposed rule, please go to: http://www.epa.gov/nsr/actions.html#2009. Alternately, you may contact me at (919) 828-0577 ext. 121 or matt@rsgengineers.com with any questions.

Welcome

2009-10-02T16:03:00.001-04:00

Welcome to the RSG Engineering Blog.