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New Air Quality Regulations and Your Solid Waste Facility

This presentation, delivered by Kyle Heitkamp of ENVIRON International Corporation at the SWANA NW Symposium, provides a comprehensive overview of the recent updates to National Ambient Air Quality Standards (NAAQS), including new regulations on NO2, SO2, and PM2.5. It covers the implications for solid waste facilities, including the New Source Review (NSR), Hazardous Air Pollutant (HAP) regulations, and greenhouse gas reporting requirements. Key changes in federal and state regulations, particularly regarding the Washington Administrative Code, are discussed to ensure compliance and operational efficiency.

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New Air Quality Regulations and Your Solid Waste Facility

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  1. New Air Quality Regulations and Your Solid Waste Facility Kyle Heitkamp, ENVIRON International Corporation Friday, April 15, 2011 SWANA NW Symposium Everett, Washington

  2. Overview • New NAAQS – National Ambient Air Quality Standards • 1-hour NO2, 1-hour SO2, Ozone, PM2.5, Lead • New Source Review (NSR) • Hazardous Air Pollutant Regulations (NESHAP or MACT) • Greenhouse Gas Reporting • Federal and State Requirements • Recent Changes to Washington Administrative Code (WAC)

  3. 1-Hour NO2 NAAQS • Annual NO2 NAAQS threshold has been around for years. • 1-hour NAAQS (100 ppb) Format: 3-year average of 98th percentile of daily maximum 1-hour NO2 concentration • 98th percentile = 8th highest daily max 1-hour NO2 with complete year • Secondary NO2 NAAQS also under consideration

  4. 1-Hour SO2NAAQS • 1-hour SO2 NAAQS (75 ppb) Format: 3-year average of 99th percentile of daily maximum 1-hour SO2 concentration • 99th percentile = 4th highest daily max 1-hour SO2 with complete year • EPA will eventually revoke 24-hour and annual SO2NAAQS • EPA also reviewing secondary SO2 NAAQS

  5. PM2.5 NAAQS • Different from other NAAQS • Includes Primary and Secondary PM2.5 Components • 24-hour NAAQS (35 μg/m3) Format: 3-year average of 98th percentile 24-hour average PM2.5 concentration • EPA reviewing annual standard • Draft by November 2010 • Final by July 2011

  6. NAAQS • Significant Impact Levels (SILs), Prevention of Significant Deterioration (PSD) Increments

  7. New Source Review Update • Major Source versus Minor Source • 100 tpy – Title V Major Source • 250 tpy – New Source Review Major Source (PSD) • 10 tpy / 25 tpy Hazardous Air Pollutant Major Source • Federal Greenhouse Gas Tailoring Rule • On July 1, 2011….. • 100,000 tpy CO2e Threshold • Biogenic Emissions versus Anthropogenic • Title V – Air Operating Permit, Fees, etc. • PSD Permitting – Complex permitting and dispersion modeling requirements, Endangered Species Act Consultation, etc.

  8. Hazardous Air Pollutant Regulations • Major Source versus Area Source • Boiler MACT (40 CFR 63, Subpart DDDDD) and Area Source MACT • Emission Limits (PM, HCl, Hg, CO, Dioxins/Furans), Work Practice Requirements, and Energy Assessment. • Natural gas-fired boilers are subject to tune-up requirements instead of emission limits. • Other gaseous fuels (i.e. LFG gas) can be grouped with nat. gas depending on H2S content (4 ppmv) and Hg content (40 mg/m3). • http://www.epa.gov/ttn/atw/boiler/boilerpg.html

  9. Hazardous Air Pollutant Regulations • Area Source Boiler MACT (40 CFR 63, Subpart JJJJJJ) • Emission Limits (PM, CO, and possibly Hg), Work Practice Requirements, and Energy Assessment. • Gas-fired boilers (natural gas, LFG, biogas, etc.) are exempt. • http://www.epa.gov/ttn/atw/boiler/boilerpg.html • Commercial/Industrial Solid Waste Incinerators (40 CFR 60, Subpart DDDD) • Actually a New Source Performance Standard (new and existing sources) • Emission limits (PM, Cd, CO, HCl, Pb, Hg, NOx, and SOx) • What is defined as a solid waste? • http://www.epa.gov/ttn/atw/129/ciwi/ciwipg.html

  10. Hazardous Air Pollutant Regulations • Reciprocating Internal Combustion Engine (RICE) – 40 CFR 63, Subpart ZZZZ • Area Source and Major Source Requirements • Special requirements for emergency engines • 50 hrs/yr non-emergency operation • Emission limits, maintenance requirements, non-resettable hour meter installation, record keeping and reporting. • http://www.epa.gov/ttn/atw/rice/ricepg.html • Useful flowcharts and regulation tools.

  11. Greenhouse Gas Reporting • Federal Mandatory Greenhouse Gas Reporting (40 CFR 82) • Monitoring, recordkeeping, and reporting • Written GHG Monitoring Plan by 1/1/2010 • Reporting Threshold • “Always In” source types • Facilities ≥ 25,000 metric tons CO2e • March 31, 2011 reporting deadline? • Some sources have specific requirements: • Subpart C – Fuel Combustion Sources • Subpart HH – MSW Landfill • Landfill gas to Energy Plants

  12. Federal GHG Report Components • Name, Address • Date, Year/Months covered • Emissions (see next slide) • Changes to previously used calculation methods • Description of monitoring methods, if “best available monitoring method” is used • Missing data applications • Certification statement

  13. Federal GHG Report Components • http://www.epa.gov/climatechange/emissions/ghgrulemaking.html • Source-specific resources and frequently asked questions

  14. Washington GHG Reporting • Finalized 12/1/2010 • First reported year will be in 2013 (report 2012 emissions) • Reporting Threshold = 10,000 metric tons CO2e • Facility reporting based on EPA methods • Fuel Supplier reporting based on tax reports to DOL • No Mobile Source Fleet reporting • Reports were due March 31 • http://www.ecy.wa.gov/programs/air/globalwarm_RegHaze/GreenHouseGasreporting_rule.html

  15. Oregon GHG Reporting • Reporting Rule developed in 2008, and updated 2010 • Applicability: • Facilities that emit ≥ 2,500 metric tons CO2e • Gasoline, Diesel, and Aircraft Fuel Dealers subject to fuel taxes or distribute ≥ 5,500 gallons of fuel • Investor and Consumer owned utilities • Use EPA emission calculation methodologies • Excel forms and online tool provided for reporting • Reports were due March 31 or date annual report is due • http://www.deq.state.or.us/aq/climate/reporting.htm

  16. Washington Admin. Code Changes • Ecology overhauled various parts of WAC • 173-460 (Toxic Air Pollutants) – June 2009 • 173-400 (General Regulations) – Effective April 1, 2011 • Summary of Changes • Replaced portable/temporary source rule with a new nonroad engine rule (173-400-035) • New emergency engine rule (173-400-930) • Updated notice of construction (NOC) emission exemptions (173-400-110(5)) • PM2.5 = 0.5 tpy • GHGs are exempt from minor source new source review (NSR) • GHGs are not exempt from major source NSR (PSD).

  17. Conclusions • Many New and updated regulations to be ready for! • Will Your Facility be a Major Source of GHGs? • Title V Permit • New project going to trigger PSD Permitting? • Are you ready for State or Federal GHG Reporting? • Monitoring plan and recordkeeping in place • Registered for Federal Electronic Reporting • Do you have a Boiler or Engine Subject to NESHAP/MACT requirements? • Applicability Determination • Notification, review applicable requirements, recordkeeping, reporting • Many changes are yet to come, keep up-to-date through Local, State, and Federal organizations.

  18. Questions and Discussion Contact Information Kyle Heitkamp ENVIRON International Corporation kheitkamp@environcorp.com 425-412-1803

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