Dec 18, 2009

Greenhouse Gas Reporting Rule Summary

EPA | Landfills | Solid Waste

On September 22, 2009, the U.S. Environmental Protection Agency (EPA) issued a final rule for mandatory reporting of greenhouse gases (GHGs) from large GHG emissions sources in the United States, including certain municipal solid waste (MSW) landfills. According to the rule, sources that generate GHGs exceeding 25,000 metric tons of carbon dioxide equivalent (tCO2e) must monitor and report these emissions to EPA. For comparison, a typical affected landfill may have:

• Landfill gas (LFG) flow rates approx. 240 cubic feet per minute (cfm) at 50% methane, and
• Waste acceptance of 50,000 tons per year or more of waste over a 15-year period.

Facilities with MSW landfills that accepted waste on or after January 1, 1980 and generate methane (CH4) in amounts equivalent to 25,000 tCO2e or more per year are subject to the rule. The 25,000 tCO2e threshold is based on the amount of CH4 generated from a facility’s landfill(s) (adjusted for soil oxidation, but not considering whether any gas is collected and destroyed) and not the amount of CH4 actually emitted. If a single facility contains multiple landfills, then the sum of each landfill’s generated CH4 emissions must be used to determine if the facility exceeds the 25,000 tCO2e per year threshold for reporting. Emissions monitoring requirements begin January 1, 2010, with the first reports due March 31, 2011.

A landfill subject to the rule must report its “actual” CH4 emissions. For landfills with no collection system, actual emissions equal generated emissions. For landfills that do collect and destroy LFG, methane destroyed in flares, engines, or other devices is deducted to determine actual emissions. As a result, these facilities must monitor the following:

1. Gas flow rate;
2. CH4 concentration;
3. Gas temperature; and
4. Gas pressure.

With the exception of gas flow rate, these parameters must be recorded at a minimum frequency of once per week. Flow rate must be monitored continuously.

Note: Per EPA’s response to our inquiry, passive vent flares do not constitute “collection and control”, and are therefore not required to be monitored for the above parameters. These flares are to be ignored for reporting purposes.
Landfills without collection and control systems are required to record incoming MSW and biosolids waste streams separately, at a minimum.

Deadlines

• January 1, 2010 – Begin recording data for reporting
• January 28, 2010 – Submit requests for extension of use of best available monitoring methods beyond March 31, 2010
• March 31, 2010 – Implement monitoring and meter calibration practices required by rule, and discontinue best available monitoring methods
• December 31, 2010 – Complete 2010 data generation
• January 30, 2011 – Submit certificate of representation to EPA, designating person(s) responsible for report submittal (NOTE: Outside consultants may be designated).
• March 31, 2011 – Submit GHG report for 2010
• ONGOING – Submit corrected report within 45 days of discovery of reporting error(s).

“Industrial” landfills are not required to report 2010 emissions, HOWEVER; EPA anticipates reporting will be required in 2011. Construction and demolition landfills may be included in this category.

In addition to this final rule, EPA has also proposed a rule for the mandatory control of GHG emissions from MSW landfills with the potential to emit 25,000 tCO2e or more per year. This rule is in the public comment period, which ends December 27, 2009.

Please feel free to contact RSG at (919) 828-0577 x121 or matt@brenta4.sg-host.com with any questions related to either of these proposed or final rules.

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