MSW landfill emissions

October 17, 2024

EPA updated its Compliance and Emissions Data Reporting Interface (CEDRI) for the electronic reporting of air emissions under the NESHAP related to MSW landfills. Three new reporting templates were added on October 15, 2024, each linked to its corresponding Excel spreadsheet template. These include the

• 1981(h) Semi-Annual Report (link)
• 1982(i) Bio-reactor 40% Moisture Report (link)
• 1981(c) NMOC Emission Rate Report (link)

The Semi-Annual report is the most significant because MSW landfills have 90 days to begin using the Excel template. Reports due January 13, 2025, or any time after that must include this electronic filing.

EPA’s color-coded template provides a bit of instruction.

The gray tab (Company Information) contains general information likely to be unchanged from report to report. After completing the gray tab, you may save the workbook as a site-specific template to use in subsequent reports to limit subsequent data entry.

Complete the green tabs (Certification, CMS Info, Description of Changes, Exceedances, and Number of Exceedances) as appropriate to complete the semi-annual report.

Complete the blue tabs (Deviation Detail, Deviation Summary, CMS Detail, and CMS Summary) if deviations or CMS out-of-control periods or downtime periods occur according to §63.10(e) and as defined in §63.1990.

The orange tabs (Well Expansion, Operational Statements, Site Specific Treatment, Enhanced Monitoring, Bypass CDT Not Operating, and Corrective Action Analysis) cover information required by the semi-annual report requirements of §63.1981(h); be sure to complete the requisite tabs.

Professionals at SCS Engineers will post more guidance but plan to continue preparing our clients’ semi-annual reports as we do now, and completing and submitting this spreadsheet. Please work with your air emissions specialist or project manager, or contact us for support.

Additional Resources:

• NESHAP Compliance
• Clean Air Act
• CEDRI Reporting Rules

August 28, 2024

Recent EPA AP-42, Compilation of Air Pollutant Emissions Factors from Stationary Sources Update Regarding Municipal Solid Waste Landfills

A revision to AP-42 regarding Municipal Solid Waste (MSW) Landfills was finalized on August 15, 2024. AP-42 is the Compilation of Air Pollutant Emission Factors guidance developed by the U.S. Environmental Protection Agency (EPA) to evaluate air pollution emissions from various sources. EPA drafted new emission factors for the MSW Landfill portion of AP-42 on January 12, 2024 and offered a 60-day public comment period that ended March 12, 2024.

Highlights of this final action include:

• Removal of the first order kinetic equation to calculate methane generation rate and replaced with the Mandatory Greenhouse Gas Reporting equation HH-1 found in 40 CFR 98.343(a)(1).
  • The New Source Performance Standards (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAP) still reference the use of k and lo values found in AP-42, even though those references have been taken out of AP-42 alongside the first order equation.

   

• Default concentrations of NMOC have been finalized for co-disposal sites prior to 1992 of 2400 ppmv and for non-co-disposal sites of 600 ppmv for pre 1992 site and 550 ppmv for after 1992 sites.
  • Additionally, EPA concluded that Non-Methane Organic Compound (NMOC) emissions are a good surrogate for Volatile Organic Compound (VOC) emissions, and removed the reference to a 39% ratio of VOC to NMOC.

   

• EPA combined emission factors for secondary compounds exiting open flares and enclosed combustors and provided additional NMOC emission factors for engines at various loads while lowering emission factors for nitrous oxide and carbon monoxide.

For additional information, please contact SCS Engineers, or visit the EPA Air Emissions Factors and Quantification website.