pat sullivan

January 4, 2016

Two EPA landfill gas rules were published in the Federal Register in August 2015. The proposed EG Guideline rule affects “new” and “existing” landfill sites. Remember, these are guidelines only. Your local and state government agencies will use them to develop and implement the actual rules by which you do business.

Learn more in one place by reading the recent article in Waste Advantage Magazine, the SCS Engineers Technical Bulletin, and a slide set from a recent webinar about what you can expect for your business. All authored by Pat Sullivan, Senior Vice President at SCS and our National Expert on the Landfill Clean Air Act; NSPS.

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November 10, 2015

Technical bulletins provide salient information in a condensed format. These summaries are useful to understand and start to plan for potential impacts to your business. Both bulletins posted today include deadlines and additional resources with contact information to help answer your questions. The two bulletins posted today are as follows:

• Summary of the Clean Power Plan includes the final standards for new and existing Electric Utility Generating Units (EGUs). The Technical Bulletin reviews the U.S. EPA determination that  the best system of emission reduction (BSER) consists of three building blocks; how the EPA determines the degree of emission limitation achievable through the application of the BSER for each type of unit; and how quickly and to what extent the measures encompassed by the building blocks could be used to reduce emissions. States will be required to submit a final plan, or an initial submittal with an extension request, by September 6, 2016. The types of plans and cost-effective strategies suggested for states to tailor their plans to meet their respective energy, environmental, and economic needs and goals, and those of their local communities is in the final sections.
• Summary of Proposed Oil and Gas NSPS U.S. EPA promulgated an amended Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (NSPS). Specifically, EPA proposed amendments to 40 Code of Federal Regulations (CFR) Part 60, Subpart OOOO and proposed an entirely new Subpart OOOOa. EPA also promulgated a draft control technique guidelines (CTGs) document for the oil and natural gas industry. The CTG is intended to provide state, local and tribal air agencies with information to assist them in determining reasonably available control technology (RACT) for reducing volatile organic compounds (VOC) emissions from select oil and natural gas industry emission sources in ozone nonattainment areas. Comments on the proposal are due November 17, 2015, and the final rules are slated to be promulgated in June 2016. Rule details are provided in the Technical Bulletin and table within the Technical Bulletin.

Clicking the title of each Technical Bulletin will take you to the full text. Each Bulletin may be shared, emailed, or printed.

About Pat Sullivan:

Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.

Click on Pat’s name to see his full qualifications and experience.

November 9, 2015

DDC Journal recently published an interesting article by Pat Sullivan, “Developing power plants that reduce environmental impacts.” http://viewer.zmags.com/publication/097d62a6#/097d62a6/24

Pat Sullivan, BCES, CPP, REPA, is a Senior Vice President of SCS Engineers and our National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). Mr. Sullivan has over 25 years of environmental engineering experience, specializing in solid and hazardous waste-related issues.

October 19, 2015

SWANA Landfill Gas & Biogas Tech News, October 2015

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Leadership Note
By Patrick S. Sullivan, REPA, CPP, BCES, Division Vice Director

The SWANA Landfill Gas and Biogas Division is very busy right now with several important efforts. On the Rules and Regulations front, the U.S. EPA has promulgated two draft landfill gas (LFG) rules that were published in the Federal Register on August 27, 2015. These include a draft Emission Guideline (EG) rule and a supplemental draft New Source Performance Standards (NSPS) rule.

The proposed EG rule affects “existing” landfill sites (i.e., landfills that have not been expanded and were not newly constructed after July 17, 2014). The NSPS rule is a supplemental proposal that affects “new” landfill sites (landfills that are new or were expanded in capacity after July 17, 2014). Comments on both are due by October 26, 2015. Final issuance of both rules is expected in the first quarter of 2016. The Division Rules and Regulation and Advocacy committees are working together to develop SWANA’s industry comments on the rules.

The major focus of both rules is the current 50 Mg/year of non-methane organic compounds (NMOCs) emission threshold, which triggers the installation of a LFG collection and control system (GCCS). In the proposed rules, that threshold will be lowered to 34 Mg/year for all landfills except existing, closed sites. This appears to be the centerpiece of the U.S. EPA’s plan to create additional NMOC and methane reductions from landfills. With a lowered NMOC threshold, some landfills, particularly those that have been too small to trigger the installation of a GCCS, will be required to install them.

Other key components of the draft EG rule, which are likely to be similar in the NSPS rule, include the following:

• A definition of LFG treatment.
• Additional surface emissions monitoring (SEM) requirements.
• A new Tier 4 methodology using surface emissions monitoring to avoid or delay GCCS installation.
• Updated LFG wellhead criteria to exclude limits for oxygen and temperature.
• Additional options for removal of the GCCS in non-producing areas.
• Elimination of the Startup, Shutdown, and Malfunction (SSM) exemption contained within current versions of the rules.

The draft EG rule also provides clarifications on several existing rule topics, as well as topics where U.S. EPA decided not to include such items in the rule:

• GCCS Design Plans.
• Organics Diversion.
• Best System of Emission Reductions (BSER).
• Electronic Reporting.
• NMOC Test Methods.
• Waste Definitions.
• Early Collection.

During the comment period, the EPA also is looking for public comment on:

• Defining closed areas and how such areas should be regulated under the rule.
• Implementing enhanced SEM requirements.
• Defining “wet” landfills and how such landfills should be regulated under the rule.
• Monitoring LFG flow at wellhead and uses of that data.
• Third-party GCCS Design Plan certifications to relieve the burden on state/local agencies and speed up plan approvals.
• Using portable meters for compliance with U.S. EPA Methods 3A and 3C (nitrogen and oxygen).

The EPA will have the ability to add more provisions to the final version of the rule based on the information submitted as a part of these information requests. This means the industry must make a strong case to the EPA to get them to consider our opinions on these issues.

Comments on this article should be addressed to Patrick S. Sullivan, Senior Vice President, SCS Engineers, at 916-361-1297 or