August 2, 2016
On July 15, 2016, the USEPA released a new final amended rule limiting emissions of greenhouse gases (GHGs) and other compounds from both existing and newly-constructed municipal solid waste landfills. This is the first modification to the federal landfill emission rule in 20 years and, for the first time, addresses GHG emissions. There has been the realization lately that any approach to successfully reduce GHG emissions nationally mist include reduction of methane emissions, a major component of landfill gas, because it is 21 times more potent on a mass basis than the main GHG, CO2, which had been the focus of most GHG reduction strategies. Therefore, came this focus on amending the main federal municipal landfill air quality rule.
Newly-constructed or modified landfills after July 17, 2014 will have emission limits found in New Source Performance Standards (NSPS) or Sect. 111(b) of CAA. See https://www3.epa.gov/ttn/atw/landfill/landfills-nsps-2060-am08-final-signature.pdf For existing landfills built before this date, emission guidelines have been published to be implemented by each state in their specific plans. See https://www3.epa.gov/ttn/atw/landfill/landfills-eg-2060-as23-final-signature.pdf. The USEPA estimates that the new standards will cover over 1,100 new and existing landfills at a combined compliance cost of approximately $60 million by 2025.
The new standards apply to landfills that have design capacities of 2.5 million metric tons and 2.5 million cubic meters or more of waste, no change in the current rules promulgated in 1996. Under both the rule and the guidelines, facilities that meet the design thresholds and emit over 34 metric tons of non-methane organic compounds (NMOC) per year will be required to install a gas collection control system (GCCS), such as flares, an enclosed combustion system for energy generation, or gas treatment system for its sale or beneficial use. A landfill may be exempt from GCCS requirements even if it meets this applicability threshold if it can demonstrate that the surface NMOC concentration is below 500 ppm for consecutive quarters.
The rule and guidelines will take effect 60 days after publication in the Federal Register (which has not occurred yet as this article is posted). Any facility that exceed the design capacity and NMOC emissions thresholds will have 30 months to install GCCS. The USEPA estimated that > 100 newly-built or modified landfills will install GCCS by 2025.
Capturing landfill gas can be beneficial as it is combustible and can be useful in generating electricity, heat, or hot water. So while being mandated to capture landfill gas can be costly, it is a “free” source of energy that can be converted to useful energy to reduce your energy costs.
CCES can provide for you the technical portion of the advice to determine which federal and state air quality rules are applicable to you and the most cost-effective strategies to maintain compliance. Contact us today at 914-584-6720 or at karell@CCESworld.com.