Smith+Gardner Blog

Joan Smyth

Proposed Updates to the Landfill Emission Guidelines and New Source Performance Standards

On August 14, 2015, EPA updated previously proposed revisions to rules regulating emissions from municipal solid waste landfills.  On July 17, 2014, EPA issued 40 CFR Part 60, Subpart XXX – Proposed Standards of Performance for Municipal Solid Waste Landfills.  This rule, when finalized, will be applicable to landfills that commenced construction, reconstruction, or modification on or after July 17, 2014.

As of the date of this writing, Subpart XXX has not been finalized.  However, the supplemental proposal issued August 14, 2015 effectively lowers the proposed non-methane organic compound (NMOC) emission threshold from 40 megagrams per year (Mg/yr) to 34 Mg/yr.  EPA estimates that this reduction will increase the number of landfills required to install landfill gas collection and control systems (LFGCCS) under Subpart XXX to 127 facilities.

EPA is requesting comment to this supplemental proposal for 60 days following its publication in the Federal Register.  A public hearing will also be held if so requested within 5 days after publication.  Instructions on commenting, requesting a public hearing, as well as information regarding the proposal may be found at the link below:

Also on August 14, 2015, EPA proposed Subpart Cf – Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills.   This follows comment on EPA’s previously issued Advanced Notice of Public Rule Making (ANPRM).  The newly proposed Subpart Cf when finalized would apply to landfills that accepted waste on or after November 8, 1987, and commenced construction, reconstruction, or modification before July 17, 2014.

Subpart Cf adopts the same 34 Mg/yr NMOC emission rate threshold requiring LFGCCS as Subpart XXX.  EPA estimates this will result in 106 additional landfills having to collect and destroy LFG.  The Tier 1, Tier 2, and (rarely used) Tier 3 methods for determining NMOC emission rates as found in Subparts Cc and WWW are retained in Subpart Cf.  In addition, a new Tier 4 method is added.  If any of Tiers 1, 2, and 3 determine that LFGCCS installation is required, Tier 4 surface emissions monitoring may be conducted.  If the Tier 4 monitoring results are all under 500 ppmv for 4 consecutive quarters, no LFGCCS is required.

Additionally, Subpart Cf is proposing to define a landfill gas treatment system as a system that “filters, de-waters, and compresses LFG” for sale or beneficial use. The proposed definition does not include specific temperature levels included in Subpart XXX, but does require a monitoring plan be developed to record parameters to demonstrate these 3 criteria are satisfied.

Wellhead operational standards under the proposed Subpart Cf would no longer require compliance with oxygen or temperature wellhead operational limits.  However, these parameters would continue to be required to be monitored on a monthly basis.  The operational requirement to continue to operate wellheads at negative pressure remains in the Subpart.

In addition, Subpart Cf proposes to:

– Allow closed landfills to continue to be subject to the 50 Mg/yr threshold for LFGCCS installation;

  •        – Excess emissions limits and reporting requirements will apply even during Startup, Shutdown, and Malfunction (SSM) events; and
  •        – Allow a closed landfill or inactive portion of an active landfill to remove LFGCCS in low-producing areas; provided that:

o   The landfill is closed, or is a closed portion of an active landfill;

o   The LFGCCS has been operated for at least 15 years, or it can be demonstrated that the LFGCCS will not be able to operate for 15 years due to declining flow; and

o   Landfill surface emissions monitoring results in the area are under 500 ppmv for 4 consecutive quarters.

Of major concern is that this proposal does not close the door on the other aspects of the ANPRM that are not included.  The proposal asks for comments on these remaining aspects, including:

  •        – Reducing surface emissions monitoring coverage from 30 meters to 25 feet;
  •        – Addressing wet landfills;
  •        – Monitoring wellhead flow rates; and
  •        – Establishing a program for third-party design plan certification.

As with the NSPS, comment on the Subpart Cf is open for 60 days following publish date in the federal register, and a public hearing may be requested within 5 days after the publish date.

Instructions on commenting, requesting a public hearing, as well as information regarding the proposal may be found at the link on the previous page.

Additionally, Matt Lamb may be contacted directly to discuss options for commenting to EPA at



Joan Smyth

Mixed Waste Processing – Is It Right for You?

Mixed Waste Processing (MWP), where all waste is processed to remove recyclables, is being considered by counties that want to increase recycling in a way that is easy for their customers.  The assumption is the public won’t have to do anything but throw waste away, and recycling will be achieved.   however, there are some considerations to be made to determine if it might be the right process for you.  These considerations include:

What are your goals? Defined goals with solid reasoning behind them, is key to determining the best options or combination of options to increase waste diversion and/or recycling.

Who controls the waste you expect to process? A MWP requires a large capital investment and without control of the waste stream, the economics of the system could change dramatically over time.

What is the composition of your current waste stream? This is important to understand what type of recovery systems would be most effective, and to understand the economics of what you will be recovering.

Will construction of a MWP reduce recycling by individuals who already do so?  If you already have a clean stream of source separated recyclables, your tonnage may reduce when customers “unlearn” the habit of separating, thus leaving you with less high quality recyclables for revenue generation.

What is the population density?  More populated areas typically have more options to increase recycling and those should be considered as well.

Is waste compacted during collection?  This can increase the rejection rate of recovered recyclables due to contamination with organics.

What does the commercial waste stream look like?  Diversion and recycling may be more easily achieved by approaching commercial entities rather than residential.

Typically, higher diversion/recycling rates are only achieved through a variety of systems working in concert to attain a specific goal.  These systems may include recycling education, optimization of convenience centers, organics diversion and composting, evaluation of commercial diversion/recycling and consideration of waste to energy (WTE) if there is an end-user in your area in addition to a MWP facility.  There is no “one option” to achieve high diversion/recycling rates and each county is different.  If you have questions regarding how to increase recycling/diversion, contact Joan Smyth at


Joan Smyth

S+G Welcomes R. Chevis Strange, Jr.

Smith Gardner, Inc. is pleased to welcome R. Chevis Strange, Jr. to our Columbia, South Carolina office.  Mr. Strange has 20 years of experience in the environmental and solid waste industry.  His experience includes environmental monitoring, stormwater monitoring, construction management,  and consulting for Municipal Solid Waste and Construction and Demolition Debris management facilities as well as compost facilities, transfer stations,  and mining facilities.  His focus on environmental field studies coupled with his associates degree in Civil Engineering give an added value to field services capabilities.


Joan Smyth

Smith Gardner Welcomes Mike Brinchek, P.E.


Raleigh, NC – Raleigh-based solid waste engineering and consulting firm Smith Gardner, Inc. announces Mike Brinchek, P.E. has joined the firm as Senior Project Manager in their Raleigh, North Carolina office.

Mike has over 17 years of experience in solid waste management and water resources.  Mike’s solid waste experience includes planning, permitting, design, and construction of solid waste facilities including landfills, solid waste transfer stations, and convenience centers.  Mike has significant experience with siting, design, permitting, construction, and closure of municipal solid waste (MSW) and construction and demolition debris (C&D) landfills and the design of stormwater collection, conveyance, and treatment for both landfill and non-landfill facilities.  He also has experience with the planning and analysis of several solid waste programs across North Carolina.

Mike is a licensed Professional Engineer in North Carolina and holds both Bachelors (Environmental Engineering) and Masters Degrees (Civil Engineering) from N.C. State University.  Mike currently serves as Secretary of the North Carolina Chapter of the Solid Waste Association of North America (SWANA) and is the local representative on SWANA’s International Board of Directors.

“Mike’s passion for the solid waste industry is clear in his work and in his active leadership roles with SWANA at both the State and International levels.  Mike brings a wealth of experience working with all types of solid waste facilities and will be an asset for our clients as well as our staff.” said Pieter Scheer, P.E., Vice President.

For more information contact:

Pieter K. Scheer, P.E.

Vice President

919.828.0577 x123


Joan Smyth

Stacey Smith, P.E. Appointed to NC Professional Engineering Board


Raleigh, NC – Smith Gardner, Inc. is pleased to announce that Stacey A. Smith, P.E., President, has been appointed by Governor Pat McCrory to serve as an engineering member of the North Carolina Board of Examiners for Engineers and Surveyors, Mr. Smith will serve as one of nine Board members who are charged with the licensure of over 25,000 individuals and 3,500 firms practicing engineering and surveying in North Carolina.

Mr. Smith, P.E., said “Thank you to my friends, family and colleagues for your support through the appointment process. It is a great honor to be chosen for this position.”

Mr. Smith is a graduate of North Carolina State University with a Bachelor of Science in Civil Engineering (Construction Option) and a Master of Science in Civil Engineering..    Since 2007, Mr. Smith has been President of Smith Gardner, Inc., a firm that provides engineering and environmental services to a variety of clients including the solid waste industry.  Mr. Smith holds a seat on the Research Council of the Environmental Research and Education Foundation, an organization dedicated  to funding and directing scientific research and educational initiatives for waste management practices to benefit industry participants and the communities they serve.

You can read more about Mr. Smith’s appointment in this article from NC State University’s Department of Civil, Construction & Environmental Engineering.





Joan Smyth

New NCDENR Guidance for Monitoring Submittals

Below is a memorandum recently sent by NCDENR.  This memorandum summarizes submittal requirements for groundwater, landfill gas and soil monitoring reports including requirements for certain forms, maps, tables and the convention for which exceedances are shown on tables.   S+G reports already meet these requirements with the exception of the file name requirement, and all future reports will comply with these requirements.  Please contact Joan Smyth ( if you have any specific questions about monitoring at your site.


To:          Solid Waste Directors, Public Works Directors, Landfill Operators, and Landfill Owners

 From:     Solid Waste Section

 Re:         Groundwater, Surface Water, Soil, Sediment, and Landfill Gas Electronic Document Submittal

The Solid Waste Section is continuing its efforts to improve efficiencies in document management.  All groundwater, surface water, soil, sediment, and landfill gas documents submitted to the Solid Waste Section are stored electronically and are made readily available for the public to view on our webpage.  Please remember that hard copies/paper copies are not required, and should not be submitted.  The submittal of these electronic documents following a consistent electronic document protocol will also assist us in our review.  Please follow these procedures when submitting all groundwater, surface water, soil, sediment, and landfill gas documents to the Solid Waste Section.

Submittal Method and Formatting

  • All files must be in portable document format (pdf) except for Electronic Data Deliverables (EDDs) unless otherwise specified by the Solid Waste Section.  All pdf files should meet these requirements:
    • Optical Characteristic Recognition (OCR) applied;
    • Minimum of 300 dpi;
    • Free of password protections and/or encryptions (applies to EDDs as well);
    • Optimized to reduce file size; and
    • Please begin using the following naming convention when submitting all electronic files:  Permit Number (00-00)_Date of Document (YYYYMMDD).  For example: 00-00_20140101.
  • Please submit all files via email or by file transfer protocol (FTP) via email to the appropriate Hydrogeologist unless otherwise specified by the Solid Waste Section.  If the electronic file is greater than 20 MB, please submit the file via FTP or on a CD.  If submitting a CD, please mail the CD to the appropriate Hydrogeologist.  The CD should be labeled with the facility name, permit number, county, name of document, date of monitoring event (if applicable), and the date of document.
  • Please be sure a signed Environmental Monitoring Data Form is submitted as part of the electronic file for all water quality and landfill gas documents (monitoring, alternate source demonstration, assessment, investigation, corrective action).  This completed form should be the first page of the document before the cover/title page and should not be submitted as an individual file.  Blank forms can be downloaded at

Monitoring Data

Monitoring data documents may include any or all of the following: 1) groundwater and surface water monitoring; 2) soil and sediment, and 3) landfill gas monitoring.  In addition to the above procedures, at a minimum, please include the following:

Groundwater and Surface Water Monitoring

  • A copy of the laboratory report(s).
  • A copy of the sampling log(s).
  • A separate table of detections and exceedances for each monitoring location.
    • All analytical results should be reported in micrograms per liter (ug/L) except for field parameters and specific Monitored Natural Attenuation (MNA) parameters.
    • Please also include the laboratory’s method detection limit (MDL) in ug/L, the Solid Waste Section Limit (SWSL) in ug/L, the appropriate NC regulatory standard in ug/L (2L, 2B, GWPS, IMAC), and the Federal Maximum Contaminant Level (MCL) in ug/L.
    • Please BOLD each exceedance result.
  • A separate table of field parameters for each monitoring location.
  • An Electronic Data Deliverable (EDD) spreadsheet for each monitoring event submitted in the correct format.  All analytical results should be reported in micrograms per liter (ug/L) except for field parameters and specific Monitored Natural Attenuation (MNA) parameters.  The blank EDD template can be downloaded at  Please pay attention to the formats within the spreadsheet.  Any EDD received that is not formatted correctly will be emailed back to be resubmitted via email within five (5) days.
  • A separate groundwater monitoring well construction table.
    • Please also include the date the well was drilled, well diameter, total well depth, depth to top of screened interval (in feet), screened interval (in feet), geology of screened interval, TOC elevation, ground elevation, groundwater elevation, GPS coordinates (latitude and longitude), and depth to water (in feet).
  • A separate groundwater table with groundwater flow rate(s).
  • A recent facility figure that includes labeled groundwater and surface water monitoring locations.
  • A groundwater flow map with an arrow(s) indicating flow direction(s), including date the measurements were taken.

Soil and Sediment Sampling

  • A copy of the laboratory report(s).
  • A copy of the sampling log(s).
  • A separate table of detections and exceedances for each sampling location.
    • Please also include the results in micrograms per liter (ug/L), the laboratory’s method detection limit (MDL) in ug/L, and the appropriate NC regulatory standard (PSRG) in ug/L.
    • Please BOLD each exceedance result.
  • A separate table of soil and/or sediment characteristics.
  • A recent facility figure that includes labeled sampling locations.

Landfill Gas Monitoring

If you have any questions or concerns regarding electronic submittals, please feel free to contact the Hydrogeologist overseeing your facility.  The Solid Waste Section greatly appreciates your assistance on this matter.  Working together, we can continue to provide excellent customer service to you and to the public.



Joan Smyth

Closed Landfill Becomes International Dark Sky Park


A closed landfill and home of Energy Xchange, which uses landfill gas for greenhouses and artist’s studios, now has a new designation.  The site was recently named the Blue Ridge Observatory and Star Park, which is the first dark sky park certified by the International Dark Sky Association in the Southeastern U.S.  Future plans for the site, located 6 miles west of Spruce Pine, North Carolina,  include an observatory with a 34-inch telescope which will be open to the public.  More information can be found at:


photo courtesy of Maryland Community College


Joan Smyth

Renewable Energy in Georgia

S+G would like to congratulate our client Phoenix Solar on completion of the largest continuous solar plant East of the Mississippi. The construction video below is quite impressive.



Joan Smyth

Landfill Gas In the News

Joan Smyth

Revisions to the Greenhouse Gas Reporting Rule Increase Reporting Requirements for Landfills

EPA recently made amendments to 40 CFR Part 98, the Greenhouse Gas Reporting Rule. These changes may have major implications on emissions calculations and reporting across all sectors, including municipal solid waste (MSW) landfills (Subpart HH) and industrial landfills (Subpart TT). A pre-publication copy of the amendments was made public on November 15, 2013, and may be downloaded from the following link, along with fact sheets and additional information:

This final rule is effective on January 1, 2014.

The most significant change impacts the likelihood of pollutant emissions to exceed reporting thresholds. A total of 23 global warming potential (GWP) values (100-year time horizon) have been revised in Table A-1 to Subpart A of the Rule. These values are used to convert calculated GHG emissions to carbon dioxide equivalent (CO2e) values, which are then compared to the reporting threshold of 25,000 CO2e. The most notable change affecting Subparts HH and TT is to the GWP for methane, which is increased from 21 to 25. The impact is felt by landfills that were previously below the reporting threshold.  Under the old GWP of 21, landfills that generated 1,190 metric tonnes of methane would not be required to report.  Now, with the new methane GWP of 25, landfills generating 1,000 metric tonnes of methane would be subject to the reporting rule.

In response to comments, landfills and other facilities that were beneath the reporting threshold for reporting year 2012 but now exceed the reporting threshold due only to the increase in GWP are not required to report 2013 emissions. For landfills specifically, the following conditions are in place for this exemption to apply:

1. No waste was accepted on or after January 1, 2013;
2. The landfill generated less than 1,190 tonnes of methane in 2013; and
3. The landfill was not required to report in any reporting year prior to 2013.

Landfills not meeting the above exemption that are newly subject to reporting as a result of the changes to GWP values are required to begin collecting data on January 1, 2014 for the 2014 reporting year. These reporters are required to submit their first reports, covering the 2014 reporting year, by March 31, 2015.

Additional changes are made to several factors used in calculating GHG emissions, including Degradable Organic Carbon (DOC) and density of methane. Data collection frequency requirements have also been relaxed from weekly to monthly for methane and other parameters.

For additional information, please feel free to contact me at or at (919) 828-0577.