THE IMPACT OF NEW AIR REGULATIONS ON LANDFILL EXPANSION

摘要

The application of regulations under the Clean Air Act to landfills has created a new set of issues that must be addressed in order to obtain a permit for a landfill expansion. These regulations include Title V, New Source Review (NSR), and Prevention of Significant Deterioration (PSD). The reason these regulations now apply to landfills is their new-found status as an emission source in and of themselves (i.e., the landfill mass emits pollutants from the surface and must be permitted as any other source). The impact of these regulations on a proposed expansion depends on the attainment status of the landfill location. Today's trend for larger landfills makes it easy to trigger major source regulations, particularly in nonattainment areas.rnLandfills that are considering an expansion with emissions that exceed de minimum levels, or any landfill considering an expansion which in and of itself is a major source, must perform New Source Review. As part of this process, emissions offsets must be obtained in nonattainment areas in order to obtain the desired air permit for the expansion. Under normal circumstances, these offsets would be for volatile organic compounds (VOC) emissions, which is the primary pollutant emitted by a landfill. Major source classification sometimes can be avoided by agreeing to permit conditions that would lower the potential to emit VOCs below major source thresholds (e.g., installing landfill gas (LFG) collection facilities as the landfill grows). The typical gas collectionrnsystem will combust the gas on site either in flare or engine generator. The downside to this is the nitrogen oxide (NOx) emissions from such combustion devices may also trigger major source thresholds such that some landfills in nonattainment areas cannot avoid the requirement for emissions offsets to expand. This paper provides: (1) strategies in obtaining air permits for landfill expansions; (2) requirements for emissions offsets; and, (3) discussion of opportunities for other landfills that may be able to create emission reduction credits for future trading or sale to those landfills that need offsets.