What’s your next move?
The opportunities and risks presented by the final Climate Change rules and legislation call for a strategic response. BT2 believes our clients need to quantify their GHG emissions before they can manage that risk and seize the opportunities. The finalized Mandatory Reporting Rule could require you to keep records starting January 1st. Whether you are managing an active landfill or monitoring a closed site, you need to know now whether you exceed the threshold.
BT2 is an experienced leader in landfill gas evaluation. We are currently performing surface emissions monitoring and air emission inventories for several landfills. We have worked side by side with our clients to research and evaluate methods of measuring and estimating methane emissions, and have provided input to regulators based on the findings of our work. BT2 is a proven leader in the industrial and municipal solid waste field, with extensive experience in landfill design, permitting, gas and leachate management, monitoring, and closure. We also provide air permitting and emission inventory calculations for a wide variety of clients.
We recommend that you begin now in order to be prepared for the inevitable changes to your testing and reporting requirements. We can work with you to prepare a low cost initial evaluation of your GHG Emissions Inventory, including a list of the new record keeping and testing requirements.
BT2's Solid Waste Team Please contact Tom Karwoski, Solid Waste Project Manager at 608.216.7369 or tkarwoski@bt2inc.com for more information.
Municipal Landfills
Landfills have the potential to affect Greenhouse Gas (GHG) levels through emissions of methane. Methane and carbon dioxide are generated biologically in a landfill as the organic matter breaks down and decays. For modern landfills, the majority of the methane that is generated is destroyed before it is emitted to the atmosphere. Methane is destroyed both by oxidation in the landfill cover soils and by collection and combustion in the landfill’s gas control system. One of the major challenges for landfill GHG reporting is figuring out how to quantify the generation and destruction of methane in the landfill environment.
Although landfill gas is composed of an approximately 50/50 mixture of methane (CH4) and carbon dioxide (CO2), it is the CH4 component that has the greatest potential impact, because it has a global warming potential approximately 21 times that of CO2. The U.S. EPA estimates that approximately one quarter of all the methane emissions in the U.S. come from landfills, and that this represents slightly less than 2% of the total U.S. GHG emissions. The EPA’s evolving Mandatory Reporting of Greenhouse Gases Rule would require landfills to submit detailed annual reports of methane emissions.
To see the EPA's fact sheet on this issue, click this link - http://epa.gov/climatechange/emissions/downloads/Landfills.pdf
Landfills are one of the few sources in the U.S. Greenhouse Gas Inventory that have decreased GHG emissions relative to the first inventory completed in 1990. Modern landfills have significantly reduced the rate of GHG emissions by collecting and burning landfill gas. Increasingly, the gas is burned for energy recovery to produce electricity or heat.
According to the USEPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2007, the volume of methane generated from U.S. landfills increased from 184 to 270 teragrams carbon dioxide equivalent since 1990, but emissions decreased, because increasing proportions of the total were destroyed through flaring and gas-to-energy projects.
Who Must Report?
The rule only includes Municipal Solid Waste (MSW) landfills. At this time industrial landfills, such as food processing facilities, hazardous waste landfills and construction and demolition landfills are not included.
The final rule applies to any MSW landfill, open or closed, that generates methane in amounts equal to 25,000 metric tons carbon dioxide equivalent per year (mCO2e). The source category consists of the landfill, landfill gas collection systems, and landfill gas combustion systems (including flares). MSW Landfills that have not accepted waste since Jan. 1 1980 are excluded from the rule.
To determine the quantity of methane generated and emitted, the EPA included a combination of modeling and direct measurements, using site-specific waste data when available and appropriate default values for other factors. The final rule requires a minimum of weekly sampling for any landfill with a gas collection system. This could be a costly upgrade for a landfill with a flare where gas volume and methane content are not monitored.
You will need to make a determination whether your facility is below the threshold. This may involve a quick screen analysis, but could also require a full analysis if emissions are near the threshold.
What Must you Report?
In addition to the amount of methane generated, you must report methane oxidation, methane destruction (if applicable) and net methane emissions on an annual basis, using both the first order decay (FOD) model and, if applicable, gas flow data for landfills with gas collection systems. You must also report the input data needed for these calculations.
The EPA method consists of a combination of the Intergovernmental Panel on Climate Change (IPCC) First Order Decay Model and site-specific direct measurements.
In addition, you must report GHG emissions of CO2, CH4, and N2O from stationary fuel combustion devices. This includes fuel used with flares for pilot gas or to supplement the heating value of the landfill gas.
Record Keeping
In order to meet the reporting requirements, you must have a system to measure and collect a significant amount of data. This information will likely exceed that currently required under your air operating permit or solid waste landfill monitoring program.
To see the EPA's February 2009 technical document on the landfill sector, click this link - http://epa.gov/climatechange/emissions/downloads/tsd/TSD%20Landfills_EPA_02%2004%2009_2.pdf
BT2 has a core team of experienced engineers, hydrogeologists, and technicians that stand ready to design a methane reporting program for your site. We’re staying on top of new developments in GHG science and policy to keep you informed and prepared.