Author: Ralph Hirshberg, P.E.
The U.S. EPA promulgated the Mandatory Greenhouse Gas Reporting Rule (GHG Rule) on October 30, 2009. Sections applicable to Municipal Solid Waste (MSW) Landfills include various provisions of the general requirements (Subparts A, B and C) as well as Subpart HH which sets forth MSW Landfill compliance obligations. The Rule becomes effective December 29, 2009 with key provisions of the GHG Rule, including obligations regarding data collection, beginning on January 1, 2010.
In general, the portions of the GHG Rule applicable to MSW landfills appears to have been crafted following the protocol for GHG accounting established by various international organizations including the United Nations Framework Convention on Climate Change (UNFCCC). Several calculation methodologies and “verification” procedures included in the GHG Rule mimic those established by the UNFCCC and the associated Intergovernmental Panel on Climate Change (IPCC). As a result, the GHG Rule is not well coordinated with existing Clean Air Act (CAA) standards already applicable to MSW landfills.
Although a convincing argument can be made that all of the data required by the GHG Rule could easily be gathered under existing CAA regulations within a reasonable degree of accuracy and repeatability and with no additional cost for affected landfill facilities, that approach is not acceptable under the GHG Rule. In general, most MSW landfills currently fall short of minimum GHG Rule requirements for both landfill gas metering and sampling frequency. CEC has developed an alternative strategic GHG compliance strategy to reduce the cost of complying with the GHG Rule.
In summary, two specific standards – 98.343(b)(1) and 98.343(b)(2) – are set forth in the GHG Rule for measurement of landfill gas volume and methane content. For the purposes of this discussion, each standard is referred to by its paragraph designation, namely b(1) and b(2):
- Standard b(1) represents the most rigorous and costly compliance option, requiring considerable and costly upgrades in existing flow and methane measurement equipment for most MSW landfill facilities. For compliance with standard b(1) “spec” metering equipment must conform to 40 CFR §98.344 and includes use of gas chromatographs for methane content determination and differential pressure meters for flow determination (various alternates/options are also available although costs are comparable). Implementation of this standard would require upgrade of both flow and methane content measurement devices for most MSW Landfill facilities at an estimated cost of approximately $50,000 per facility.
- Standard b(2) in comparison is less rigorous with respect to equipment specifications and costs, but potentially more labor intensive, requiring weekly monitoring of various gas flow and methane content parameters. However, at least a portion of existing “non-spec” gas monitoring equipment (flow meters) can be utilized at most facilities. This will result in lesser initial capital costs for equipment but may result in increased long-term costs (e.g., labor) if weekly manual monitoring is utilized. However, if b(2) level monitoring is coupled with remote data collection, savings of long-term labor costs will be realized. Based on the most cost efficient strategy evaluated by CEC under this standard, implementation costs are estimated at $25,000 per facility.
CEC notes that landfills already equipped with flow and methane monitoring equipment meeting the “b(1)” or §98.344 specifications are obligated to use this equipment for data GHG emission calculations. Section III.HH of the GHG Rule preamble as well as paragraphs b(1) and b(2) which set forth these requirements are listed as follows:
Preamble Section III.HH. “We do require landfill gas collection systems already equipped with continuous monitoring systems to determine daily average flow and concentrations and to use these data in their gas recovery calculations. For collection systems that do not have continuous gas monitors, weekly sampling is required. Weekly monitoring provides an adequate number of samples to evaluate the variability and uncertainty associated with methane generation.”
§98.343 (b)(1). “…If you continuously monitor the flow rate, CH4 concentration, temperature, pressure, and moisture content of the landfill gas that is collected and routed to a destruction device (before any treatment equipment) using a monitoring meter specifically for CH4 gas, as specified in § 98.344, you must use this monitoring system and calculate the quantity of CH4 recovered for destruction using Equation HH–4 of this section. A fully integrated system that directly reports CH4 content requires no other calculation than summing the results of all monitoring periods for a given year.”.”
§98.343 (b)(2). “If you do not continuously monitor according to paragraph (b)(1) of this section, you must determine the flow rate, CH4 concentration, temperature, pressure, and moisture content of the landfill gas that is collected and routed to a destruction device (before any treatment equipment) at least weekly according to the requirements in paragraphs (b)(2)(i) through (b)(2)(iii) of this section…”
CEC would be pleased to provide a compliance summary for your facility. Items to be evaluated include:
- Does your landfill generate more than 25,000 metric tons of CO2e?
- Are you prepared to collect the required data from your landfill?
- Have you cataloged all of your stationary sources of combustion?
Please call Ralph Hirshberg at CEC Greenhouse Gas Help Line 1-888-364-2324 or Email your questions to LFGHG.Help@CECinc.com.