Title V Permitting & Compliance
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Title V Permitting
LaBella maintains a professionally qualified engineering staff to offer a wide range of Clean Air Act Title V permitting services. Our permitting services include preparing the permit applications for issuance and renewal, as well as preparing permit modifications for the installation of new flares and compliance with 40 CFR Part 60 Subparts XXX and OOO. We also review existing permits, along with the applicable regulations, to ensure compliance in all aspects of the Title V Permit.
Title V Monitoring
As required by Title V permits, LaBella performs quarterly surface emissions monitoring (SEM). Areas along the pathway that show exceedances above 500 parts per million of methane above background will be flagged so landfill personnel can make necessary cap repairs. In addition, sump houses, designated riser pipes, and/or leachate clean-outs are monitored for the presence of methane.
To maintain compliance with Title V permits, LaBella has developed a protocol for and conducted numerous Tier 2 Nonmethane Organic Compound (NMOC) field testing events. Our protocol is consistent with the requirements of 40 CFR 60.754.a.3. We install the sampling probes in accordance with US EPA Method 25 and then collect air samples for analysis, evaluate the data, and prepare the Tier 2 NMOC Emission Report.
Title V Reporting
LaBella routinely prepares the numerous reports required by the NSPS and Emissions Guidelines (EG) for MSW landfills. These reports include the following:
- Initial Design Capacity Reports
- Tier 1 NMOC Emissions Reports
- Tier 2 NMOC Emissions Reports
- Control System Design Plans
- Initial Performance Test Report
- Annual Compliance Reports
- Semiannual Collection and Control System Reports
- Semiannual Startup-Shutdown-Malfunction (SSM) Reports
- Quarterly Surface Emissions Monitoring Reports
- Annual Emissions Inventory Reports
We ensure our clients remain in compliance with these requirements. Additionally, in accordance with the federal Greenhouse Gas Inventory Regulations, LaBella prepares the Annual Greenhouse Gas Reports for landfills that emit 25,000 metric tons or more of carbon dioxide equivalent per year. LaBella has successfully petitioned the US EPA for “not required to report” status for several of our clients.
