Landfills

Landfills

Landfills Air Pollution Air Compliance and Enforcement Jeff Meyer 1 Overview Landfill Overview Emissions Permit Applicability Potential to Emit Permit Requirements Federal Regulations 2

Landfill Overview 846 Landfill sites in New Jersey 830 Closed and no longer accepting waste 13 Active Commercial Landfills 3 Active Private Landfills 3 NJDEP APROVED COMMERCIAL SANITARY LANDFILLS Landfill NJEMS PI # Class City Waste Types Phone Number

Atlantic County UA 143393 I Egg Harbor Township 10,13,13C,23,25,27 (609) 272-6950 (609) 646-5500 Burlington County 150098 I Mansfield /Florence Twps.

10,13,13C,23,25, 27,27I (609) 499-5303 Cape May Cty MUA 154930 I Upper Twp./Woddbine Borough 10,13,13C,23, 25,27,27I (609) 861-5701 (609) 465-9026 I Deerfield Twp.

10,13,13C,23,25, 27,27I (856) 825-3700 133530 Gloucester County IA 132199 I South Harrison Twp. 10,13,13C,23,25, 27,27I (856) 478-6045 Keegan Landfill (NJMC)

133571 II Kearny 13,13C,27 (201) 460-4678 132314 I East Brunswick 10,13,13C,23, 25,27, TRMW (1-7) (732) 246-4313

10,13,13C,23, 25,27,27I (732) 922-8686 Cumberland County IA Middlesex County UA 133927 I Tinton Falls Monmouth County Ocean County LF Corp 133642 I

Manchester 10,13,13C,23,25, 27,27I, TRMW (2-7) (732) 657-5100 Pennsauken -PCFACC 132037 I Pennsauken 10,13,13C,23, 25,27,27I (856) 663-2772 www.pcfacc.com/psl.htm

I Alloway Township 10,13,13C,23, 25,27,27I (856) 935-7900 132608 Salem County UA Sussex County 132675 I Lafayette Township Warren County

132759 I White Township 4 10,13,13C,23, 25,27,27I, TRMW (2-7) (973) 579-6998 10,13,13C,23, 25,27,27I, TRMW (2-7) (908) 453-2174 ext.223 5

NJDEP APPROVED OPERATING PRIVATE SANITARY LANDFILLS Landfill ID# Class City DuPont A&B 1713B II Deepwater Hercules 1436B

II Kenvil Phillipsburg Associates III 2119E II Phillipsburg Waste Types 13,27 13,13C, 23,27 13,27

6 Landfill Air Emissions Primary source: Landfill itself LFG is a by-product of the decomposition of municipal solid waste (MSW): ~50% methane (CH4) ~50% carbon dioxide (CO2) <1% non-methane organic compounds (NMOCs) Hazardous air pollutants (HAP) Greenhouse gases (GHG) Volatile organic compounds (VOC) Other non-organic compounds (e.g. hydrogen sulfide) Gas generation, including rate and composition, proceeds through phases. Phase duration rate of gas generation varies with landfill conditions, i.e.: Waste composition Design Cover materials Climatic conditions 7 Other sources: Combustion products from engines, flares, turbines, boilers, and

particulate from roads and waste handling. Landfill Gas (LFG) Concerns May contribute to ground level ozone formation Cause an odor nuisance Cause a fire potential due to methane migration Contribute to toxics and HAPs in ambient air which can cause health problems Contribute to climate change problems due to large emissions of carbon dioxide and methane. 8 LFG Collection Systems Active collection systems pressure gradient created by use of mechanical blowers or compressors in order to extract LFG .

Passive collection systems Active System natural pressure gradient created by the increased pressure within the landfill from LFG generation to mobilize the gas for collection or venting. Which type of system depends upon the landfill characteristics & operating practices. Gas extraction wells may be installed at the landfill perimeter, but are typically installed within the refuse of a landfill. depth and spacing of wells vary with landfill characteristics and operations (i.e., lined or unlined, waste type, LFG generation, etc.) Offsite migration probes are often installed at the landfill perimeter for monitoring the operation of the collection system. 9 FLIR (Forward Looking Infrared) Video of landfill gas from different points

10 LFG Control & Treatment Combustion Energy Recovery OR No Energy Recovery gas turbines flares (open or enclosed) internal combustion engines boiler-to-steam turbine systems Purification use of adsorption, absorption, and membranes to remove water (H2O), CO2, H2S,NMOCs, and siloxanes. Can process LFG to pipeline quality natural gas 11

Who needs an Air Permit? NJAC 7:27-8: PERMITS AND CERTIFICATES FOR MINOR FACILITIES (AND MAJOR FACILITIES WITHOUT AN OPERATING PERMIT) 8.2(c) Any equipment or source operation that may emit one or more air contaminants, except (CO2), directly or indirectly into the outdoor air and belongs to one of the categories listed below, is a significant source (and therefore requires a preconstruction permit and an operating certificate), unless it is exempted 8.2(c)17. Equipment used for the purpose of venting a closed or operating dump, sanitary landfill, hazardous waste landfill, or other solid waste facility, directly or indirectly into the outdoor atmosphere including, but not limited to, any transfer station, recycling facility, or municipal solid waste composting facility; 12 NJAC 7:27-22: OPERATING PERMITS 7:27-22.2 Applicability (a) 1. A facility which emits or has the potential to emit a Hazardous Air Pollutant (HAP) in an amount which equals or exceeds the amounts listed in (a)1i through iv below. For the purposes of this paragraph, the

calculation of potential to emit shall include fugitive emissions, as defined at N.J.A.C. 7:27-22.1. i. 10 tons per year of any HAP; ii. 25 tons per year of any combination of HAPs; iii. Such lesser quantity of any HAP as the EPA may establish by rule, pursuant to 42 USC 7412(a)(1), as the threshold amount for a major HAP facility. iv. Such quantity of any radionuclides as the EPA may establish by rule. OR 13 NJAC 7:27-22: OPERATING PERMITS 7:27-22.2 Applicability (a)2. A facility which emits or has the potential to emit any of the air contaminants listed below in Table 1, in an amount which equals or exceeds the threshold amount for that contaminant. Emissions of carbon dioxide (CO2) are not to be used in determining applicability under this section. Air contaminant Threshold Level Carbon Monoxide 100 tons per year

PM-10 100 tons per year TSP 100 tons per year Sulfur Dioxide100 tons per year Oxides of Nitrogen 25 tons per year VOC 25 tons per year Lead 10 tons per year Any other Air Contaminant, except CO2 100 tons per year **Shall include fugitive emissions if facility falls under stationary source categories regulated by a standard promulgated under 42 U.S.C. 7411, Standards of Performance for New Stationary Sources. However, for a facility in this category, fugitive emissions need only be included when calculating the potential to emit those air contaminants which EPA has regulated for that stationary source category. 14 Potential to Emit How do I determine potential to emit? Potential to Emit (PTE)-max amount of emissions that can be generated by the landfill and all its associated equipment (flares, generators, etc.) at max physical capacity. PTE is very different from actual emissions.

Uncontrolled landfill emissions-primarily Methane (CH4) and Carbon Dioxide (CO2), which are greenhouse gases and must be included in the calculation of Carbon Dioxide Equivalents (CO2e), and some Non-Methane Organic Compounds (NMOC). Can do the calculations manually using information from EPAs AP-42 document at www.epa.gov/ttn/chief/ap42/ch02/index.html, chapter 2.4, using default or sitespecific data. Alternative- use EPAs LandGEM model (available at the same Web address), which is a Microsoft Excel spreadsheet-based model that calculates annual emissions of total LFG, CH4, CO2, and NMOC using user inputs. The model uses information from AP-42 for gas concentrations, but also allows additional user input if site specific data is available. Also account for the additional emissions that result from the combustion of LFG units that burn fuel other than LFG Emission factors are in AP-42, depending on the type of combustion equipment. Be sure to document the source of all emission factors used for all calculations. 15 NJDEP Air Quality Permitting Program State of the Art (SOTA) Manual for Equipment Used to Vent Landfills

Developed June 2010 Made public but is still DRAFT Used for guidance Each landfill permit application is evaluated on a case by case basis SOTA applies to: all newly constructed, reconstructed or modified equipment emits contaminants in excess of their SOTA thresholds used for the purpose of venting a closed or operating dump, sanitary landfill, hazardous waste landfill, directly or indirectly into the outdoor atmosphere which are subject to the SOTA provisions of the New Jersey Administrative Code (N.J.A.C.) 7:27-8 and N.J.A.C. 7:2722. 16 Emissions-SOTA Applicability When accounting for the emissions to determine SOTA applicability.

Potential to Emit Emissions for the equipment should include, but may not be limited to all collected air contaminant emissions that are discharged through a stack through passive or active venting all uncollected air contaminant emissions that are not emitted to the atmosphere through a stack. 17 SOTA Thresholds-Preconstruction Permit SOTA thresholds for source operations which must obtain a Preconstruction Permit pursuant to N.J.A.C. 7:27-8 can be found in Appendix I. Appendix I, Table 1 lists the SOTA threshold for any air contaminant as 5 tons per year (tpy). Any air contaminant is defined in this section as: any 112 (r) contaminant; any stratospheric ozone depleting substance, or any greenhouse gas except carbon dioxide (CO2). Consequently, the SOTA threshold for methane is 5 tpy. 18

SOTA Thresholds-Operating Permit The SOTA thresholds for source operations which must obtain an Operating Permit, pursuant to N.J.A.C. 7:27-22, can be found at N.J.A.C. 7:27-22.35 (b) Threshold for Hazardous Air Pollutants are the de minimis levels specified by the EPA pursuant to 42 U.S.C. 7412(g) and the threshold for any other air contaminant is 5 tpy. N.J.A.C. 7:27-22 defines Air contaminant as any substance, other than water or distillates of air, present in the atmosphere as solid particles, liquid particles, vapors or gases 19 SOTA Performance Levels SOTA performance levels are not a substitution for complying with any applicable regulations contained in the N.J.A.C. 7:27. Other sections of N.J.A.C. 7:27 which may be applicable include, but may not be limited to, the following: 1) N.J.A.C. 7:27-5 Prohibition of Air Pollution (includes odor provisions) 2) N.J.A.C. 7:27-7 Sulfur

3) N.J.A.C. 7:27-17 Control and Prohibition of Air Pollution by Toxic Substances 4) N.J.A.C. 7:27-18 Control and Prohibition of Air Pollution from New or Altered Sources Affecting Ambient Air Quality (Emission Offset Rules) 5) N.J.A.C. 7:27-19 Control and Prohibition of Air Pollution by Oxides of Nitrogen. 20 SOTA Performance Levels: Landfills Subject to MACT (Maximum Achievable Control Technology ) Pursuant to N.J.A.C. 7:27-8.12(e)3 for preconstruction permits and pursuant to N.J.A.C. 7:27-22.35(c) for operating permits: If subject to 40 CFR 63, Subpart AAAA, then compliance with all of the provisions of that MACT standard is equivalent to SOTA for any HAPs. This applies solely to the emissions of individual HAPs. Other contaminants and contaminant categories, such as total suspended particulates and total volatile organic compounds, may be subject to other requirements.

21 SOTA Performance Levels: Landfills not subject to MACT OR Landfills subject to MACT that have contaminants that are not HAPs emitted in excess of SOTA levels METHANE: No control device is necessary for methane if the landfill gas methane concentration is < 20% by volume or the landfill gas flow rate is < 5 cubic feet per minute (ft3/min), as measured at the venting or extraction well. SOTA performance standards for methane emissions, where the methane concentration is 20% by volume and the landfill gas flow rate is 5 cubic feet per minute (ft3/min), refer to table on following slide.. 22 SOTA performance stds for methane emissions, where methane concentraction 20% by vol. & landfill gas flow rate is 5 ft3/min. Landfill Gas Methane Concentration (LGMC)-LGMC (% by volume) / Landfill

Gas Flow Rate(LGFR) (ft3/min) - * SOTA Performance Standards 1. LGMC 20%; and < 35%; and 2. LGFR to 5 ft3/min. Spark ignited flare or equivalent 1. LGMC 20%; and 2. LGFR 5 ft3/min and < 150 ft3/ min. 1. LGMC 35%; and 2. LGFR 150 ft3/min. Spark ignited flare or equivalent 1. A. Landfill Gas Collection Efficiency of at least 75%; or B. Methane concentrations of 500 ppmv, for instantaneous surface monitoring and 25 ppmv for integrated surface monitoring; and

2. A. Destruction and Removal Efficiency of at least 98%; or B. Less than 20 parts per million by volume dry basis (ppmv), as equivalent hexane, corrected to 3% oxygen at the outlet of the combustion unit. * as measured at the venting or extraction well 23 Table continued Instantaneous surface monitoring: monitoring to determine the methane concentration in excess of background & obtaining the reading at the time of the measurement. Such monitoring may include taking a sample 0-3 inches above the landfill and using a portable flame ionization detector to instantaneously measure the methane concentration. Integrated surface monitoring : monitoring a set number of landfill grids to determine the methane concentration. Such monitoring may include taking a sample 0-3 inches above the landfill and collecting that sample over an 8-10 hour period. 24

SOTA Performance Standards -VOCs Refer to the previous table for Methane SOTA Performance Standards. 25 NOx SOTA Performance Standards Oxides of Nitrogen (NOx): shall be achieved if the LGMC* is 35% and the LGFR* 150 ft3/min: Type of Combustion Device NO x SOTA performance standards Flare 0.025 pounds per Million British Thermal Unit Internal Combustion Engine

0.6 grams per brake horsepower-hour Turbine 25 ppmvd @ 15% O2 *LGMC -Landfill Gas Methane Concentration *LGFR- Landfill Gas Flow Rate 26 SO2 SOTA Performance Standards Sulfur dioxide (SO2): shall be achieved if the LGMC* 35% and the LGFR* 150 ft3/min: A minimum 95% removal of all sulfur compounds, extracted by the landfill gas collection system, prior to the combustion device; or A maximum SO2 concentration of 310 parts per million, by volume, corrected to 0 (zero) % oxygen at the stack of the combustion device. *LGMC -Landfill Gas Methane Concentration *LGFR- Landfill Gas Flow Rate

27 CO SOTA Performance Standards Carbon monoxide: shall be achieved if the LGMC* 35% and the LGFR* 150 ft3/min: Type of Combustion Device CO SOTA performance standards Flare 0.06 pounds per Million British Thermal Unit Internal Combustion Engine 2.5 grams per brake horsepower-hour Turbine 130 ppmvd @ 15% O2

*LGMC -Landfill Gas Methane Concentration *LGFR- Landfill Gas Flow Rate 28 Total Suspended Particulates(TSP)/PM-10/Opacity SOTA Performance Standards Total Suspended Particulates(TSP)/PM-10/Opacity: shall be achieved if the LGMC* 35% and the LGFR* 150 ft3/min: Type of Combustion Device TSP/PM-10/Opacity Flare 1. Designed and operated consistent with the requirements in 40 CFR 60.18; and 0.06 pounds per Million British Thermal Unit or PM-10 emissions; and 2. 10% opacity, not including startup and shutdown Internal Combustion Engine 10% opacity, exclusive of condense water vapor, not including start-up and shut-down Turbine

10% opacity, exclusive of condense water vapor, not including start-up and shut-down *LGMC -Landfill Gas Methane Concentration *LGFR- Landfill Gas Flow Rate 29 ODORS Several reduced sulfur compounds are emitted from landfills have the potential to cause significant off-site problems, such as odors or health impacts. Compounds include, but are not limited to, hydrogen sulfide (H2S), methyl mercaptan (CH3SH), dimethyl sulfide ((CH3)2S), carbon disulfide (CS2) and dimethyl disulfide ((CH3)2S2). Compounds are not classified as criteria pollutants, toxic compounds, or hazardous air pollutants & do not have a SOTA emissions threshold. However, their emissions should be incorporated into any SOTA analysis for SO2 since one mechanism used to control the reduced sulfur compounds is combustion, which results in the creation of SO2.

30 ODORS All source operations covered by preconstruction permit must meet the air pollution odor provisions at N.J.A.C. 7:27-5 Prohibition of Air Pollution and N.J.A.C. 7:27-8.3(j). All source operations covered by an Operating Permit must meet the air pollution odor provisions at N.J.A.C. 7:27-5 and 7:27-22.16(g)8. No permittee shall allow any air contaminant, including those detected by sense of smell to be present in the outdoor atmosphere in a quantity and duration which is, or tends to be, injurious to human health or welfare, animal or plant life or property, or which would unreasonably interfere with the enjoyment of life or property 31 Available Technologies-Methane and VOCs The following technologies could be used to control both methane and volatile organic compounds

Continuous spark ignited flare, with a minimum spark interval of at least every 2 seconds and continuous electronic spark ignition sequence. Enclosed Flame Thermal Oxidizer with appropriately designed air intake modulators Internal Combustion Engine reciprocating or a combustion turbine in which power, produced by heat and/or pressure produced by combustion is converted to mechanical work. Combustion Turbine 32 Available Technologies - NOx The following technologies could be used to control NOx : Low NOx Burners Selective Catalytic Reduction Non-Selective Catalytic Reduction Good Combustion Practices 33 Available Technologies SO2 The following technologies could be used to control SO2: Wet scrubbing

Activated carbon used to remove the reduced sulfur compounds from the flue gas stream prior to combustion. Other adsorption media used to remove the reduced sulfur compounds from the flue gas stream prior to combustion. 34 Available Technologies- CO The following technologies could be used to control CO: Thermal oxidizer Catalyst 35 Exclusions HAPs, TXS, and any other contaminant besides methane, VOC, carbon monoxide, nitrogen oxide(s), sulfur dioxide, and total suspended particulates/PM-10/Opacity emitted above SOTA thresholds will be evaluated on a case by case basis pursuant to N.J.A.C. 7:27-8.12(e)5 for preconstruction permits and

pursuant to N.J.A.C. 7:27-22.35(c)5 for operating permits, unless the landfill is subject to MACT provisions. 36 Federal Regulations NSPS CFR Part 60 Subpart Cc NSPS CFR Part 60 Subpart WWW NESHAP 40 CFR 63 Subpart GGG NESHAP 40 Part 63 Subpart AAAA 37 NSPS CFR Part 60 Subpart Cc Applies to existing MSW landfill for which construction, reconstruction, or modification commenced before May 30, 1991.

Landfills closed prior to November 8, 1987 are not regulated by Subpart Cc Cc has same requirements as and refers to WWW No size cut-off for Cc applicability Applies to open and closed landfills DOES NOT APPLY TO NJ BECAUSE THERE IS NO STATE PLAN (refer to 40CFR62 Subpart GGG instead) 38 NSPS CFR Part 60 Subpart WWW Subpart WWW applies to: MSW landfills that commenced construction, reconstruction or modification after May 30, 1991 Modification: increase in volume design capacity by either horizontal or vertical expansion No size cut-off for WWW applicability Applies to open and closed landfills 39 WWW Requirements

All sources, regardless of size must submit a design capacity* report on the capacity of the landfill Submit amended report if small landfill increases capacity 2.5 million megagrams or million cubic meters Due 90 days after date of commencing construction/modification /reconstruction *Design capacity is maximum amount of waste a landfill can ultimately accept. 40 Design Capacity Report-WWW Required information to be submitted: Map or plot of landfill, identifying all areas where solid waste may be landfilled, includes closed areas Maximum design capacity If specified in permit issued by state, copy may be submitted as part of report If not in permit, calculate using good engineering practices, provide calculations in report. 41

Design capacity is 2.5 million megagrams and 2.5 million cubic meters WWW cont. Calculate NMOC (nonmethane organic compounds) emission rate < 50 megagrams/yr Submit annual emission report and recalculate annually using method in the rule. Stop when emission rate 50, requirements below, OR stop when landfill is permanently closed Submit a closure notification when closed. 50 megagrams/yr Submit collection & control design plan within 1 yr Install collection & control system as per WWW 60.752(b)(2) Shall be capable of meeting emission guidelines within 30 months after date NMOC emission rate report showed NMOC emissions 50 megagrams/yr 42 Applicability Table-WWW

based on 60.33c(a) and 60.752 Design Emissions Capacity (Mg/yr (Million Mg NMOC) &/or Million m3) Design Capacity Report Required Periodic NMOC Emission Reports Required Controls Required

Title V Permit Required <2.5 < 50 Yes No No * <2.5 50 Yes

No No * >2.5 < 50 Yes Yes No Yes >2.5 50

Yes Yes Yes Yes * part 70 or 71 requires a permit if the landfill is a major source as defined in part 70 or 71 or is subject to part 70 or 71 for some other reason (e.g., subject to another NSPS or NESHAP). A landfill is a major source and requires a title V permit if the air emissions are > 100 tons/yr or the HAP emissions are >10 tons/yr for one HAP or 25 tons/yr for a combination of HAP's or if it emits major source levels of criteria pollutants such as VOC (major source thresholds are different for attainment and nonattainment areas--see the definition in 40 CFR section 70.3(a)). 43 CFR Part 62 Subpart GGG Applies to landfills that commenced construction, reconstruction, or modification before May 30, 1991 and.. Accepted waste at any time since November 8, 1987 OR has

additional waste capacity for future waste deposition Does not apply to landfills that submitted negative declaration (defined in GGG 62.14351) letter as per GGG 62.14352(c) and Emissions, procedures, test methods, monitoring, reporting, and recordkeeping requirements refer WWW. In addition, facility must submit increments of progress reports, which are due within 10 days of completing each increment (refer to next slide) Design capacity < 2.5 million megagrams or million cubic meters Not required to obtain operating permit unless required to under another rule. 44 Table 3 to Subpart GGG of Part 62Generic Compliance Schedule and Increments of Progress Compliance date applies to landfills with design capacities 2.5 million megagrams and 2.5 million cubic meters that are subject to this subpart Increment Increment 1-Submit final control plan

Increment 2Award Contracts Increment 3Begin on-site construction Increment 4Complete on-site construction Increment 5Final compliance Date - after initial NMOC emission rate report or 1st annual emission rate report showing NMOC emissions 50 Mg/yr. 1 year 20 months 24 months 30 months 30 months Alternative dates can be submitted for approval Design capacity < 2.5 million megagrams or million cubic meters No schedule to achieve increments 45

NESHAP Part 63 Subpart AAAA State of NJ delegated authority Applicability Applies to existing and new MSW landfills Accepted waste since November 8, 1987 or has additional capacity for waste deposition and meets one of the following: Major source (as defined in 40 CFR 63.2 of Subpart A) Co-located with a Major source (as defined in 40CFR 63.2 of Sub A) Area source landfill that has a design capacity 2.5 million Mg and 2.5 million cubic meters & estimated uncontrolled emissions 50 MG/yr NMOC as calculated per WWW OR Accepted waste since November 8, 1987 or has additional capacity for waste deposition, that includes a bioreactor and meets one of the following: Major source (as defined in 40 CFR 63.2 of Subpart A) Collocated with a Major source (as defined in 40CFR 63.2 of Sub A) Area source landfill that has a design capacity 2.5 million Mg and 2.5 million cubic meters and not permanently closed as of 1/16/2003 46

Compliance Dates - AAAA Existing affected sources-commenced construction or reconstruction before November 7, 2000. (Were to comply by 1/16/2004). New affected sources commenced construction or reconstruction after November 7, 2000. (Were to comply by 1/16/2003). If a major source or co-located with a major source or an area source landfill that has a design capacity 2.5 million Mg and 2.5 million cubic meters & estimated uncontrolled emissions 50 MG/ yr NMOC as calculated per WWW Comply by date required to install collection and control system by WWW or by EPA approved and effective State plan, whichever is later No longer have to comply when do not have to apply controls as per WWW, the Federal plan, or EPA approved and effective State plan 47

Compliance Dates AAAA- Bioreactor *Were to comply by 1/16/2004 if existing or by 1/16/2003 if new affected source. If own/operate a bioreactor, landfill not permanently closed as of 1/16/2003 and has a design capacity 2.5 million Mg and 2.5 million cubic meters If existing affected source (were to run collection & control by 1/17/2006) Install a collection & control system that meets WWW, the Federal plan, or EPA approved and effective State plan, whichever earlier If new affected source OR existing and didnt initiate liquid addition to bioreactor until after 1/17/2006 Install collection & control system before initiating liquids addition Operate gas collection & control system w/in 180 days of- liquid addition OR achieving moisture content of 40% by wt (refer to AAAA 63.1980(g) and (h) for calculation details), whichever is later No longer have to comply if: meet control system removal criteria, bioreactor meets criteria for nonproductive area, or bioreactor portion of landfill is closed as per WWW. If closed, submit closure report. 48

Requirements - AAAA Comply with WWW or the Federal plan, or EPA approved and effective State plan Except annual report described in WWW (60.757(f))-submit every 6 months For approval of collection & control system alternatives refer to WWW If own/operate a bioreactor, landfill not permanently closed and has a design capacity 2.5 million Mg and 2.5 million cubic meters additional requirements Develop and maintain SSM plan (Startup, Shutdown, Malfunction plan) Submit initial semiannual compliance report & performance test results described in WWW (60.757(f)) w/in 180 days after required to operate collection & control system If submit semiannual compliance report for bioreactor and conventional portion of landfill, may delay submittal of report for bioreactor-refer to AAAA 6.1980(f)(1) through (3) 49

Questions???? 50

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