Landfill-Gas-to-Energy Projects Sergio Guerra Kansas Department of - PowerPoint PPT Presentation

Landfill-Gas-to-Energy Projects Sergio Guerra Kansas Department of Health and Environment Bureau of Air

 1.0-Background  2.0-Landfill emissions  3.0-Subpart WWW  4.0-Landfill gas beneficial projects  5.0-Incentives for LFG utilization projects  6.0-Permitting challenges

1. Background

Types of Landfills  Class I hazardous waste landfills  Municipal solid waste (MSW) landfills  Construction & demolition (C&D) landfills  Agricultural waste, mining waste, high- volume industrial waste landfills

Developing Federal Rules  Solid Waste Disposal Act of 1965  Resource Conservation and Recovery Act of 1976 (RCRA)  Subtitle C for Hazardous Waste (HW) Landfills  Subtitle D for Municipal Solid Waste (MSW) Landfills

RCRA Subtitle D  40 CFR 257 Open Dump Inventory of 1978  Required an inventory of open dumps vs. landfills  Open dumps had to upgrade or close within 5 years  Sanitary landfills could remain open  40 CFR 258 Sanitary Landfill Rules of 1991  Upgraded landfills well beyond the old definition

Subtitle D Provisions  Location Restrictions  Operating Criteria  Design Criteria  Groundwater Monitoring  Landfill Closure  Post-Closure Care  Financial Assurance

Clean Air Act Regulation  Clean Air Act (CAA) Amendments of 1990 started air regulation of landfills  Spawned landfill regulation by  New Source Performance Standards (NSPS) / Emission Guidelines (EG)  Title V  Maximum Achievable Control Technology (MACT)  New Source Review (NSR)  Prevention of Significant Deterioration (PSD)  Biggest impact is from NSPS  NSPS requires gas collection at all large landfills – includes most landfills today

2. Landfill Emissions

Landfill Gas (LFG)  Landfill gas is generated by the decomposition process in landfills  Creates mostly methane and carbon dioxide  And trace volatiles  Methane is the principal component of natural gas  Can be flammable and explosive  Can be used as a fuel

Landfill Gas (LFG)  Methane a greenhouse gas  Methane absorbs terrestrial infrared radiation (heat) that would otherwise escape to space (GHG characteristic)  Methane as GHG is over 20x more potent by weight than CO 2  Landfills were the second largest human- made source of methane in the United States in 2006, accounting for 22.6% generated

Landfill Gas Hazards  Methane can migrate from landfills and burn or explode in confined space  Has caused injury and death  Trace gases can create odor problems  Trace volatiles can create air pollution

Landfill Gas Benefits  The methane in landfill gas can be captured and used as a fuel  Common LFGE applications are:  Direct-use (boiler, heating, direct thermal)  Combined Heat & Power (engine, turbine, microturbine)  Electric (engine, turbine, microturbine)  There are 400 LFGE projects in the U.S.  And another 200 elsewhere in the world today

3. NSPS Subpart WWW  NSPS (New Source Performance Standards) for MSW Landfills, 40 CFR Part 66 Subparts Cc and WWW, promulgated March 12, 1996 requires control of landfill gas when the landfill capacity exceeds:  2.5 million m 3 AND  2.5 million megagrams AND  NMOC emissions exceed 50 megagrams/yr

Effect of the NSPS • Air Emissions become a concern • Increased scrutiny of landfill air emissions • New Permit and Regulatory Requirements  More Monitoring and Testing  More Records  More Reports

Importance of NSPS Applicability: Primary trigger based upon the landfill meeting the Area Source Criteria in 40 CFR 63.1935(a)(3)

Importance of NSPS Compliance: Landfills compliance is based upon the NSPS, EG or Approved Alternative as per the NSPS/EG (40 CFR 63.1955(a) or (c))

NSPS - Applicability The NSPS applies to MSW landfills for which construction, modification, or reconstruction commences on or after May 30, 1991

Control Requirement Design capacities greater than or equal to • 2.5 million Mg and 2.5 million m 3 NMOC Emissions Greater than 50 Mg/yr •

NMOC Emissions 40 CFR 60.754(a)(1)(i) • n M NMOC =  2 k L o M i ( e -kti ) (C NMOC ) (3.6 x10 -9 ) i= 1 • 40 CFR 60.754(a)(1)(ii) M NMOC = 2 L o R (e -kc - e -kt ) (C NMOC ) (3.6 x10 -9 )

NMOC Emission Rate 1000.00 CAA 100.00 r /Y AP-42 g M 10.00 1.00 6 6 6 6 6 6 6 6 7 8 9 0 1 2 3 4 9 9 9 0 0 0 0 0 1 1 1 2 2 2 2 2 Year

Tier 1; 40 CFR 60.754(a)(2) • No Testing Required • Default Equation Values are Used • Calculation & Report Required Within 90 days of being affected 40 CFR 60.757(b)(1)(i)(B)

Tier 2; 40 CFR 60.754(a)(3) • C NMOC Determination Required • Calculation & Report Required Within 180 days after the first 50 Mg exceedance 40 CFR 60.757(c)(1)

Tier 3; 40 CFR 60.754(a)(4) • k Determination Required • Calculation uses the Tier 2 C NMOC • Calculation & Report Required Within 1 year after the first 50 Mg exceedance 40 CFR 60.757(c)(2)

GCCS plan Landfill Gas Collection and Control System Design Plan required within 1 year of the first report which the emission rate equals or exceeds 50 Mg per year. 40 CFR 60.752(b)(2)(i) and 60.757(c)

Collection System Requirements  Maximum gas flow rate  Collect Gas from all areas in which solid waste has been placed for:  5 years or more if active; or  2 years or more if closed or at final grade.  Sufficient Extract Rate  Minimize off-site Migration

Control System : # 1 • Open flare; or • A control system designed and operated to reduce NMOC by 98% by weight; or [40 CFR 60.752(b)(2)(iii)(A) & 40 CFR 60.752(b)(2)(iii)(B)]

Control System: # 2(a) • A enclosed combustor which reduces NMOC by 98 weight percent or reduce the outlet NMOC concentration [40 CFR 60.752(b)(2)(iii)(B)]

Control System: # 2(b) Reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen.

Control System: # 3 • Route the collected gas to a treatment system that processes the collected gas for subsequent sale or use [40 CFR 60.752(b)(2)(iii)(C)]

GCCS Startup Installation of Landfill Gas Collection and Control System Completed within 30 months after reporting NMOC emissions  50 Mg/yr 40 CFR 60.752(b)(2)(ii)

Reporting Requirements # 1 • Initial and annual design capacity report • NMOC emission reports (Annual or 5 year Reports) • Notification of increases in design capacity and NMOC emissions

Reporting Requirements # 2 • Submittal of design plans and construction permit applications • Compliance certifications • System Removal Reports • Annual Emission Report • Excavation in Asbestos Areas

Recordkeeping # 1 • Control and Emission Exceedances • Location of Asbestos • Waste Acceptance Rate • Asbestos Waste Shipment Records

Recordkeeping # 2 • Gas Collection and Control Equipment Operating Parameters • New Well Installation • Monitoring Parameters

Landfill Air Regulations - MACT  MSW Landfill MACT (Maximum Achievable Control Technology), 40 CFR Part 63-Subpart AAAA applies to those NSPS regulated landfills requiring control (NMOC emissions 50 Mg/yr or more), and requires:  Immediate control of landfill gas from bioreactors  Startup, Shutdown, & Malfunction (SSM) Plan  Semiannual Reporting  Continuous monitoring of control device operating parameters

Title V Requirement  June 10, 1996 for MSW landfills that commenced construction, modification, or reconstruction on or after May 30, 1991 but before March 12, 1996;  Ninety days after the date of commenced construction, modification, or reconstruction for MSW landfills that commence construction, modification, or reconstruction on or after March 12, 1996.

4. Landfill Gas Beneficial Projects

Landfill Gas and Green Power A Winning Combination  Dual benefit  destroys methane and other organic compounds in LFG  Offsets use of nonrenewable resources (coal, oil, gas) reducing emissions of SO 2 , NO X , PM, CO 2  LFG is a recognized renewable energy resource (Green-e, EPA Green Power Partnership, 33 states, Sierra Club, NRDC)  LFG is generated 24/7 and projects have online reliability over 90%  LFG can act as a long-term price and volatility hedge against fossil fuels

Common LFGE applications  Direct-use (boiler, heating, direct thermal)  Combined Heat & Power (engine, turbine, microturbine)  Electric (engine, turbine, microturbine)

State of the National LFG Industry (April 2009)  At least 485 operational projects in 44 states supplying:  12 billion kilowatt-hours of electricity and 85 billion cubic feet of LFG to direct-use applications annually  Estimated ‘09 Annual Environmental Benefits  Carbon sequestered annually by ~ 19,500,000 acres of pine or fir forests , or  CO 2 emissions from ~ 199,000,000 barrels of oil consumed , or  Annual greenhouse gas emissions from ~ 15,700,000 passenger vehicles  Estimated Annual Energy Benefit  Powering more than 889,000 homes and heating nearly 614,000 homes