New Source Review The Stink of Permitting Projects at High TRS - PowerPoint PPT Presentation

New Source Review –The Stink of Permitting Projects at High TRS Landfills (and other Wonderful Landfill Gas Related Air Permitting Topics) 2018 S pring Conference – S WANA NJ Michael A. Trupin Trinity Consultants

Today’s Discussion ˃ Discussed: NEWS FLAS H!! There is S ulfur in your Landfill Gas and it could  impact your air permitting & compliance. ♦ Not S ampling your LFG for TRS may NOT be an option Brief Review of NS R –To Understand Permitting Challenges  Elevated TRS in LFG – NS R Implications  Formaldehyde Emissions from GTE  ˃ Not Discussed: Waste streams responsible for S ulfur in LFG  How those little bugs get that S ulfur in your LFG  Advanced NS R/ PS D topics/ regulatory aspects  NS R/ PS D Avoidance S trategies (and all the nuances of the  associated rules) ♦ Common Control; “ One time doubling” ; Air Permit “ Timing” ; etc. S pecifics of NJDEP S tate of the Art (S OTA) Requirements 

NSR in 60 Seconds (or so) ˃ Prevention of S ignificant Deterioration (PS D) – Permits for Maj or S ources in Attainment Areas  40 CFR 52.21 – Federal PS D Program ♦ NJ has delegat ed aut horit y t o implement t his regulat ion  Maj or for 1 Compound – Evaluate Applicability for all compounds ˃ Nonattainment New S ource Review (NNS R) – Permits for Maj or S ources in Nonattainment Areas  40 CFR 51, Appendix S – Federal NNS R  N.J.A.C. 7:27-18 – New Jersey’s “ NNS R”

NNSR Rules in NJ ˃ N.J.A.C. 7:27-18 – Control and Prohibition of Air Pollution from New or Altered S ources Affecting Ambient Air Quality  AKA. “ Emission Offset Rule”  AKA. “ S ubchapter 18” ˃ EP A “ Approval” for Regulation 7/ 25/ 1996 ˃ S poiler Alert!! – New Jersey NNS R Rules effectively represent potential to potential test AND include ALL increases/ decreases in contemporaneous period.

Attainment… Huh?! ˃ National Ambient Air Quality S tandards (or NAAQS )  Carbon Monoxide  Lead  Nitrogen Dioxide  PM-10  PM-2.5 – (S O2 [and others] are Precursors)  Ozone – (Regulated via NOx/ VOC Precursors)  S ulfur Dioxide

SO2 (1971) NAAQS

SO2 (2010) NAAQS

PM-2.5 (1997) NAAQS

PM-2.5 (2006) NAAQS

PM-2.5 (2012) NAAQS

Who Really Cares?! ˃ PS D – Maj or S tationary S ource (or modification to existing non-maj or)  MS W Landfill (and associated source activity) with >= 250 TPY Potential to Emit (of any [non-GHG] regulated pollutant)  Typically this does not include Fugitives

Who Really Cares?! ˃ NJ “ NNS R” Initial Applicability Criteria  Facility has PTE that equals or exceeds:  Or, Increase of an air contaminant (in application) equals or exceeds threshold.  S ubchapter 18 definition of PTE would typically include fugitive emissions.

EPA on Fugitives “…the use of collection technology by other landfill sources, whether or not subject to EPA's proposed requirements or to State implementation plan or permit requirements, creates a presumption that collection of the emissions is reasonable at other similar sources. If such a system can reasonably be designed to collect the landfill's gas emissions, then the emissions are not fugitive and should be considered in determining whether a major NSR permit is required.” ---John Seitz memo 1994 (Classification of Emissions from Landfills for NSR Applicability Purposes)

Having Major Mod Issues! ˃ PS D Maj or Modification  Physical change in or change in the method of operation of a maj or stationary source resulting in: ♦ S ignificant emission increase of PS D pollutant AND significant net emission increase

NJ Sub 18 Applicability ˃ If initial applicability criteria is met, an application is subj ect to S ub. 18 if proposed allowable emissions would result in significant net emission increase of air contaminant AND the facility location is: NA for respect ive crit eria pollut ant  At t ain. for respect ive crit eria pollut ant , and  ♦ Net Increase yields increase in [ambient] in a NA Area and ♦ Increase in [ambient] equals/ exceeds S IL in the NA Area At t ain. for respect ive crit eria pollut ant , and  ♦ Net Increase yields increase in [ambient] that equals/ exceeds S IL, AND ♦ Net Increase yields increase in [ambient] that results in violation of NAAQS or NJAAQS

This is significant (Sub 18) ˃ Increase that equals or exceeds:

Significant Net Emission Increase Determination (NJ “NNSR” Only) NI = IP + INP + IF + IA – DO – DC ˃ NI=Net Emission Increase at Facility ˃ IP=Any increase(s) in allowable emissions of the contaminant which ˃ occurred during the contemporaneous period (as authorized by permit) INP=Any increase(s) in allowable emissions of the contaminant ˃ during the contemp. period and which came from source/ control for which no permit was in effect IF=Increase in fugitive emissions during contempt. period ˃ IA=Proposed increase in allowable emissions of the air contaminant ˃ which is the subj ect of application DO=Any increase(s) in allowable emissions of the air contaminant ˃ during contemp. period, if offsets were secured ˃ DC=S um of all creditable emission reductions at the facility during contemp. period not including creditable emission reductions previously used as emission offsets.

Definitions for NJ Netting ˃ Allowable Emission - … based on the maximum rated capacity of the equipment, unless subj ect to Federally enforceable limits which restrict operating rate, hours, or both… ˃ Contemporaneous - … five years prior to commencement of construction and period up to initiation of operation ˃ Creditable Emission Reduction… typically based on the actual rate of emissions (equals average rate at which air contaminant was actually emitted during the 2 calendar years immediately preceding the permit application date)

This is significant (PSD) Carbon Monoxide: 100 TPY  Nitrogen Oxides: 40 TPY  S ulfur Dioxide: 40 TPY  Particulate Matter: 25 TPY  PM 10 : 15 TPY  PM 2.5 : 10 TPY  Ozone: 40 TPY (VOC or NOx)  Pb: 0.6 TPY  Fluorides: 3 TPY  S ulfuric Acid Mist: 7 TPY  Hydrogen S ulfide: 10 TPY  Total Reduced S ulfur: 10 TPY  Reduced S ulfur Compounds: 10 TPY  Municipal Waste Combustor Organics: 3.5 E-6  Municipal S olid Waste Landfill Emissions (NMOC): 50 TPY  All Other NS R Pollutants: Any Emission Rate!! 

Why do I care about this?! ˃ NNS R Applicability (NJ S ub 18)  Lowest Achievable Emission Rate (LAER)  Compliance certification  Emission Reductions (Offsets)  Alternative S iting Analysis  Conduct Ambient Air Quality Impact Analysis ˃ PS D Applicability  Best Available Control Technology  S ource Impact Analysis  Additional Impacts Analysis  Evaluate Impact on Class I Areas

Landfill Source Examples – Painting the Picture ˃ S ources of Concern  Landfill Emissions  Flare Emissions (Open or Enclosed)  Engine / Turbine Emissions ˃ The next slides provide example emission rates for common landfill sources  Do we have any NNS R/ PS D Concerns? !

Flare Emissions Typical Flare Emissions Open Flare Enclosed Flare PM2.5 11.17 11.17 PM10 11.17 11.17 SO2 64.46 64.46 NOx 45.21 39.89 VOC 3.44 2.63 CO 206.11 132.98 Notes: -Based on 5000 cfm of LFG (50% CH4) to Flare -Assumes 300 ppm Sulfur in LFG  SOTA Note: 2014 DRAFT Manual Proposed 95% removal of all TRS or 310 ppmv (corrected to 0% Oxygen)

Engine (Example) Emissions Typical (CAT) Engine Emissions No. of Units: 1 1 6 4 CAT 3516 CAT 3520 CAT 3516 CAT 3520 NOx 22.17 12.94 133.02 51.76 CO 34.36 89.05 206.16 356.2 VOC 0.12 0.22 0.72 0.88 PM10 2.1 3.7 12.6 14.8 PM2.5 2.1 3.7 12.6 14.8 SO2 4.29 7.56 25.74 30.24 Notes: -Based on 300 ppm Sulfur in LFG -Assumes 333 scfm (50% CH4) for 3516 -Assumes 586 scfm (50% CH4) for 3520 -VOC Excludes HCHO -Yes! You may have used different NOx or CO Factors

Quick Check on Gas Generation 1,000 TPD Receipt (k=0.04/Lo=100) Waste Accepted In-Place Total LFG Year TPY TPY Avg. cfm 1 365000 0 0 2 365000 365000 175 3 365000 730000 344 4 365000 1095000 505 5 365000 1460000 661 6 0 1825000 810 2,000 TPD Receipt (k=0.04/Lo=100) 7 0 1825000 778 8 0 1825000 748 Waste Accepted In-Place Total LFG 9 0 1825000 718 Year TPY TPY Avg. cfm 1 730000 0 0 2 730000 730000 350 3 730000 1460000 687 4 730000 2190000 1010 5 730000 2920000 1321 6 0 3650000 1620 7 0 3650000 1556 8 0 3650000 1495 9 0 3650000 1437

The NSR Impact of TRS Annual SO2 Emissions (TPY) at Constant Flow and Sulfur Concentration* Combusted LFG Flow in SCFM 500 1000 2000 3000 4000 5000 46.9 1.0 2.0 4.0 6.0 8.1 10.1 TRS Concentration (ppmv) 200 4.3 8.6 17.2 25.8 34.4 42.9 1000 21.5 42.9 85.9 128.8 171.8 214.7 2500 53.7 107.4 214.7 322.1 429.4 536.8 5000 107.4 214.7 429.4 644.1 858.9 1073.6 10000 214.7 429.4 858.9 1288.3 1717.7 2147.1 *All table values are SO2 in Units of TPY.