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Corporate Air Program
The Corporate Air Program creates, communicates and issues policies, procedures, best management practices, directives, guidance and strategies related to the protection, control and management of air quality with field operations. The Corporate Air Program also creates and issues standard templates for permit and regulatory compliance recordkeeping and reporting including GHG emissions pursuant to the EPA and Canadian GHG reporting programs. Standard recordkeeping and reporting templates have been developed and used by field operations to meet applicable federal requirements such as Title V Operating Permit Program, New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP). The Corporate Air Program develops and delivers webinar and classroom training on these topics.
The Air Program’s team develops short-term and long-term permitting and compliance strategies to accommodate existing site conditions and projected new or modified operations at our disposal operations. This includes assisting field operations with permitting beneficial use processes used to convert methane to electricity and renewable fuels. The Corporate Air Program identifies local, state and federal regulatory impacts to WM field operations. Air Directors interpret environmental data and provide guidance, direction and recommendations to field operations by preparing and reviewing compliance reports, permit applications and draft permits. The team interfaces with air regulators during the permit process and regulatory interpretative issues and supports field operations in responding to and resolving alleged violations, warnings or other potential noncompliance issues.
WM’s Air Program also prepares, compiles and presents scientific data, white papers and other technical support to facilitate changes to federal and/or state/provincial rules and guidance. Corporate Air Program directors coordinate with our field operations, as well as the legal and community affairs departments, to work directly with regulators at the federal and state/provincial level. Together, they facilitate changes to federal and state rules and permit conditions, as well as respond to proposed regulatory changes.
We also partner with industry stakeholders, academia and other Environmental Management Group Programs (i.e., engineering, landfill gas management, wastewater), to develop new and evaluate existing and emerging technology and processes that measure and mitigate emissions from disposal operations, such as combustion and fuel conversion technologies, as well as leachate evaporation technologies and fugitive landfill emissions. This includes supporting development and testing of emerging methane measurement techniques for landfill emissions.
During CY2021, there were three alleged air emissions noncompliance incidents that resulted in formal enforcement action with assumed environmental impact.