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.
2010 Greenhouse Gas Reporting Required
EPA’s December 7, 2009 announcement that CO2 is a “threat” to public health and the environment has brought additional focus to the ongoing legislative debate regarding climate change and the final Mandatory Greenhouse Gas Reporting rule (40 CFR 98). This rule was signed on September 22, 2009, published on October 30, 2009, and is effective December 29, 2009.
The rule covers approximately 85 percent of the nation’s greenhouse gas (GHG) emissions and will apply to roughly 10,000 facilities. EPA will develop an electronic reporting system for calendar year 2010. Reports for 2010 are due on March 31, 2011.
This rule requires facilities to calculate CO2 emissions or install monitoring systems where valid emission estimating methods are not currently available. This rule applies to:
- Operations that are one of 17 source categories (adipic acid production, aluminum production, ammonia manufacturing, cement production, electricity generation, HCFC-22 production, HFC-23 destruction processes, lime manufacturing, manure management systems, municipal solid waste landfills, nitric acid production, petrochemical production, petroleum refineries, phosphoric acid production, silicon carbide production, soda ash production, titanium dioxide production) unless excluded by specific caveats;
- Operations in one of seven source categories (ferroalloy production, glass production, hydrogen production, iron and steel production, lead production, pulp and paper manufacturing, zinc production) if the facility emits more than 25,000 metric tons (mt) of carbon dioxide equivalents (CO2e);
- Facilities with annual CO2e emissions from stationary fuel combustion sources (i.e., boilers, stationary internal combustion engines, process heaters, combustion turbines, and other stationary fuel combustion equipment with certain exclusions) that exceed 25,000 mt; and
- Suppliers of coal-based liquid fuels, natural gas and natural gas liquids, petroleum products, and industrial GHGs (fluorinated gases, nitrous oxide, and carbon dioxide).
To determine whether your facility is subject to the rule, you may wish to use EPA’s applicability tool.
Reporting of indirect electricity use is not required because the electricity generators will report those emissions. Portable equipment, emergency generators, emergency equipment, flares, and hazardous waste combustors (except those co-fired with fossil fuel) are exempt.
On January 1, 2010, monitoring or use of best available monitoring methods to calculate CO2e emissions must begin. EPA expects that most facilities will begin to comply with monitoring requirements by April 1, 2010, although extensions for continued use of best available monitoring beyond that date will be considered. Requests for extensions need to be submitted no later than January 28, 2010.
EPA’s stated purpose for this reporting is to collect accurate and timely data on GHG emissions data that can be used to inform future policy decisions. Expectations are that the information will be used to help establish emission baselines which will in turn impact future emission allowances, emission offsets, and carbon trading. The emissions data reported to EPA will be available to the public allowing for the identification of significant GHG emission sources.
If you are unclear about how this rule affects your facility, please contact one of CEC’s GHG experts:
Kris Macoskey (Pittsburgh), 800-365-2324, email@example.com
You may also email CEC’s GHG team for additional information at GHGENVHelp@cecinc.com.