Air Quality Standard Permit for Municipal Solid Waste Landfills

The Municipal Solid Waste Landfills (MSWLF) and Transfer Station Air Standard Permit (SP) was recently amended to clarify its scope.

Effective September 1, 2006, the new Standard Permit replaced the old standard permit for MSWLF in Title 30 Texas Administrative Code (30 TAC) Section 116.621 (relating to Municipal Solid Waste Landfills). The Standard Permit is located in 30 TAC Chapter 330, Subchapter U, and now serves as a preconstruction authorization for air contaminant emissions to the atmosphere from MSWLF and Transfer Station sites.

This new Standard Permit was expanded to include facilities commonly found at landfills and waste transfer sites, as well as authorize the beneficial use of landfill gas. The following facilities are typically found at a MSWLF or Transfer Station and may be authorized under the new Standard Permit if the facility meets the conditions for any of the Title 30 TAC Sections (Permit by Rule [PBR]) or Standard Permits listed below:

• 106.181, Used-Oil Combustion Units
• 106.183, Boilers, Heaters, and Other Combustion Devices
• Miscellaneous sources and recycling equipment that meet the requirements of 106.261 Facilities (Emissions and Distance Limitations)
• 106.433, Surface Coat Facility
• 106.436, Auto Body Refinishing Facility
• 106.451, Wet Blast Cleaning
• 106.452, Dry Abrasive Cleaning
• 106.454, Degreasing Units
• 106.472, Organic and Inorganic Liquid Loading and Unloading
• 106.492, Flares
• 106.496, Air Curtain Incinerators
• 106.512, Stationary Engines and Turbines
• Standard Permit for Pollution Control Projects
• Standard Permit for Temporary Rock Crushers
• Standard Permits for Electric Generating Units

This allows the MSWLF owner/operator to construct and operate facilities, covered under these and any other PBR's, and Standard Permits, as part of the initial or modified authorization under the new Standard Permit.

The authorization for the Standard Permit under 30 TAC Chapter 330, Subchapter U, no longer requires registration using PI-1S or PI-7 forms, multiple permitting fees, and other documentation, but will only require a Certification Form (available in PDF or Word)submitted by the landfill's Responsible Official (RO) or Duly Authorized Representative (DAR). No fee is required. When you certify, the information must show how you meet the general and specific conditions of the SP, which can easily be shown by using the SP Checklist (available in PDF or Word).

To find out whether your site may use this Standard Permit, use the "Quick Screen" (available in PDF or Word) which provides a checklist and flowchart. If your site is not able to use the Standard Permit, check the other two of the three possible preconstruction authorizations listed below for a MSWLF or Transfer Station:

• Permit by Rule, 30 TAC Section 106.534,
• Standard Permit under 30 TAC Section 330.981,
• New Source Review permit under 30 TAC Section 116.110.
• See the Guidance PDF for additional information on the various air authorizations and requirements.

Emission Calculations

As a part of determining which portions of the Standard Permit apply to a MSWLF or Transfer Station, emissions of organic compounds must be estimated. Emission calculation methods vary depending on the circumstances, but the EPA has guidance in AP-42 , and the Texas Commission on Environmental Quality (TCEQ) is developing a spreadsheet covering the most common methods. These emissions are also very important in determining the applicability of federal standards.

Federal Performance Standards

There are at least two federal standards which may apply to a MSWLF:

1. Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60), New Source Performance Standards (NSPS) Subpart WWW, Standards of Performance for Municipal Solid Waste Landfills, Sections 60.750-759.

• Landfills constructed, reconstructed, modified, or have had physical or operational changes after May 30, 1991, become applicable to NSPS WWW. To help determine if a MSWLF is subject to these regulations, use the NSPS WWW Checklist for Conditions and Requirements (available in PDF or Word).
• The SP incorporates some of the definitions, the landfill gas control requirements, the reporting, the monitoring, and the record keeping requirements in NSPS WWW. Under NSPS WWW there are a number of reports that require submittal to the TCEQ. Particularly, the GCCS design plans and AMOC require approval before proceeding. See the guidance PDF for NSPS WWW Reporting and Record keeping Submittal Forms PDF to assist submitting these reports.

2. Title 40 CFR 63, National Emissions Standards for Hazardous Air Pollutants for Source Categories, which sets out Maximum Achievable Control Technology (MACT) Standards in Subpart AAAA, National Emission Standard for Hazardous Air Pollutants: Municipal Solid Waste Landfills, Sections 63.1930 - 1990.

• To help determine if a MSWLF is subject to these regulations, use the MACT AAAA Flowchart and checklist (available in PDF or Word). Under MACT AAAA there is semi-annual reporting in addition to NSPS WWW requirements. See the guidance for MACT AAAA (available in PDF or Word) forms to assist submitting these reports

Record Keeping

Under the Standard Permit, your records must identify the rules under which your facility is operating and demonstrate compliance for a rolling 12-month period. Be sure you keep at least these records:

• a copy of the Standard Permit
• a copy of NSPS WWW or MACT AAAA and all related reports and monitoring
• records documenting compliance with the above rules.

These records must be kept on site and readily available on request for inspection by the TCEQ or any air pollution control program that has jurisdiction. If you have questions about the type of records you should keep, contact the Air Program in the TCEQ regional office that serves your county.

Questions? We Can Help

If you have questions about this or any other Standard Permit, contact us.