c/EPA
              United States
              Environmental Protection
              Agency
Air and Radiation
6202J
EPA 430-B-96-080
December 1996
              Helping Landfill Owners Achieve
              Effective, Low-Cost Compliance with
              Federal Landfill Gas Regulations
     LANDFILL METHANE
     OUTREACH PROGRAM
   Recyded/Recydabte
   Printed on paper that contains
   at least 50% recycled fber

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                              ACKNOWLEDGMENTS
SCS Engineers prepared this report under Work Assignment 1-2 of U.S. Environmental
Protection Agency Contract No. 68-W6-0004. The principal authors were Mark Najarian,
P.E., and Anne Kaufmann. The authors wish to thank Tom Kerr of the U.S.
Environmental Protection Agency for guidance and comment during the preparation of
this document.  Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.

This document is intended to be an implementation aid for landfill owners and operators.
This document does not affect in any way the requirements of the regulations as
promulgated on March 12, 1996.  Any questions or conflicts between the regulations
and this document should be directed to:

                       U.S. Environmental Protection Agency
                     Atmospheric Pollution Prevention Division
                                Methane Branch
                                Mail Code 6202 J
                               401 M. Street, SW
                            Washington, D.C. 20460
                               Tel:  202/233-9768
                               Fax: 202/233-9569

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                             TABLE OF CONTENTS
 SECTION
PAGE
 1.0    INTRODUCTION	 .  1

       Background	  1
       Purpose of this Booklet	  1

 2.0    DETERMINING APPLICABILITY	  2

       Step 1:  Is Your Landfill Affected by the Landfill Rule?	  3
       Step 2:  Is Your Landfill Regulated by the NSPS or EG?	  4
       Step 3:  Does Your Landfill Meet the Design Capacity Threshold?	  5
       Step 4:  What are Your Landfill's Annual NMOC Emissions?	  6

 3.0    MEETING THE REQUIREMENTS OF THE LANDFILL RULE	  7

       Step 1:  Submitting Compliance Reports  	  7
       Step 2:  Installing a Gas Collection System	  9
       Step 3:  Destroying LFG at 98 Percent Efficiency 	  11
       Step 4:  Adhering to Operation/Maintenance Procedures  	  11
       Step 5:  Following Recordkeeping and Reporting Requirements	  12

 4.0    MEETING THE DEADLINES	  12

 5.0    EVALUATING LFG-TO-ENERGY OPTIONS	  13

       Step 1:  Technical Overview	  13
       Step 2:  Making the Economics Work	  15

 6.0    U.S. EPA LANDFILL METHANE OUTREACH PROGRAM RESOURCES  	  19
                               LIST OF TABLES

Table 1      How to Use This Document 	  2
Table 2      Applicability Examples  	  4
Table 3      Compliance Dates for an NSPS Landfill  	 12
Table 4      Energy Recovery Cost Comparison	 16
                               LIST OF FIGURES

Figure 1      Determining Whether Your Landfill is Affected by the Landfill Rule  .... 3
Figure 2      Determining If Your Landfill is Regulated Under NSPS or EG	 5
Figure 3      The Landfill Rule Compliance Requirements  	 8
Figure 4      Schematic of a Typical Gas Extraction Well  	  10
Figure 5      Schematic of a Typical LFG Collection System	  10

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 SECTION 1.0
 Background
INTRODUCTION
 Until recently, emissions of landfill gas-comprised
 mainly of methane, carbon dioxide, and nonmethane
 organic compounds (NMOCs)-were not subject to
 federal regulation. These emissions are now regulated
 under the Clean Air Act as a result of the landfill New
 Source Performance Standards (NSPS) and Emissions
 Guidelines (EG), promulgated by the U.S.  Environmental
 Protection Agency (EPA) on March 12, 1996
 (hereinafter "the landfill rule"). Affected municipal solid
 waste landfills must collect and combust their landfill
 gas (LFG). There are two compliance options under the
 landfill rule-installation of a LFG collection system and
 flare, or installation of a LFG collection system  and an
 energy recovery system.

 Due to high methane concentration (typically 40 to 60
 percent), landfill gas is a valuable source of fuel.
 Therefore, the landfill rule presents landfill owners with
 a unique opportunity to reduce the cost of compliance
 by converting their methane into energy.  EPA can help
 owners and operators examine the options for profitable
 gas-to-energy applications through its Landfill Methane
 Outreach  Program (LMOP).  The LMOP's mission is to
 reduce methane emissions from landfills by lowering
 the barriers to and encouraging development of
 environmentally and  economically beneficial LFG-to-
 energy projects.

 Purpose of this Booklet

This booklet provides the basic information that the
owner/operator of a municipal solid waste landfill needs
to comply with the landfill rule. This booklet provides a
simple explanation of the landfill rule and discusses
how landfill gas-to-energy can be an attractive
compliance option.
                                                    The LMOP
                                                    has
                                                    partnered
                                                    with state
                                                    agencies,
                                     LANDFILL METHANE Utilities, the
                                     OUTKEACH PROGRAM [_FG-tO-
                                     energy industry, financiers
                                     and gas end users through
                                     one of three LMOP Ally
                                     programs:

                                      • The State Ally Program,

                                      • The Utility Ally Program,
                                        and

                                      • The Industry Ally
                                        Program.

                                     Through membership in the
                                     LMOP, Allies receive:

                                      • Public recognition,

                                      • Technical, financial and
                                        regulatory information,
                                        and

                                      • Promotion of LFG-to-
                                        energy as an
                                        economically and
                                        environmentally
                                        beneficial technology.

                                     The LMOP can help landfill
                                     owners and operators
                                     affected by the landfill rule
                                     identify the best options for
                                     achieving maximum environ-
                                     mental protection under the
                                     landfill rule at the lowest
                                     possible cost.

                                                         For the full text of the landfill
                                                         rule, see Federal Register,
                                                         March 12, 1996 (Volume
                                                         61, Number 49), 40 CFR
                                                         Parts 51, 52, and 60,

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TABLE 1. HOW TO USE
Question
• Is my landfill affected by the rule?




• If my landfill is affected, what do I
do next?
• What are the deadlines?
• Could I produce energy from the
gas generated at my landfill?
• How can I find other information
regarding the landfill rule and LFG-
to-energy?
THJS DOCUMENT |
Section to Consult |
Section 2.
Step 1
Step 2
Step 3
Step 4
Section 3.
Step 1
Step 2
Step 3
Step 4
Step 5
Section 4.
Section 5.
Step 1
Step 2
Section 6.
Determining Applicability 1
Is your landfill affected by the landfill
rule?
NSPS or EG - Is your landfill regulated
by the NSPS or EG?
Design Capacity - Does your landfill
meet the design capacity threshold?
Annual NMOC Emissions - What are
your landfill's annual NMOC emissions?
Meeting the Requirements
Submit Compliance Reports
Install Gas Collection System
Destroy LFG at 98 Percent Efficiency
Operation/Maintenance
Recordkeeping and Reporting
Meeting the Deadlines
Evaluating LFG-to-Energy Options
Technical Overview
Making the Economics Work
U.S. EPA Landfill Methane Outreach
Program Resources
SECTION 2.0
DETERMINING APPLICABILITY
The following sections describe the steps involved in
determining whether your landfill is affected by the
landfill rule:

   Step 1 - Is your landfill affected by the landfill rule?

   Step 2 - If so, is your landfill regulated by NSPS or
            EG?

   Step 3 - Does your landfill meet the design capacity
            threshold?

   Step 4 - What are your landfill's NMOC emissions?
                                         It is critical to remember
                                         that your landfill is not
                                         regulated by the landfill rule
                                         unless it meets all of the
                                        -tendfill rule criteria,
                                         including;

                                          •     Dates  of operation;
                                          •     Permitted size; and
                                          •     NMOC emissions

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Step 1: Is Your Landfill Affected by the Landfill Rule?

All municipal solid waste (MSW) landfills that were
active  on or after November 8, 1987 are potentially
affected by the landfill rule.  MSW landfills that
accepted hazardous waste in the past (i.e., co-disposal
landfills) are subject to the landfill rule; however,
hazardous waste landfills (RCRA Subtitle C) that accept
minimal amounts of municipal waste are nd subject to
the landfill rule.  Figure 1 provides an easy way to
determine your landfill's status under the rule.
                                    FIGURE 1
                 DETERMINING WHETHER YOUR LANDFILL
                   IS AFFECTED BY THE LANDFILL RULE
           Does (or did) the landfill accept
           municipal solid waste (MSW)?
                    Yes
          Was the landfill active on or after
                Novembers. 1987?
                    Yes
               Is the total permitted
               capacity greater than
         or equal to 2.5 million Mg of waste?
                    Yes
              Are the landfill's NMOC
              emissions greater than
               or equal to 50 Mg/yr?
                    Yes
                Installation of gas
               collection and control
                system required.
No
—>>
No
       No
           Not regulated under
               landfill rule
                                              No
    Exempt from any further
  evaluation—need only submit
  design capacity report to the
    air quality division within
   your state's environmental
   agency. See Section 2.2.
 Reevaluate NMOC emissions
 on an annual basis for every
 year the landfill accepts waste.
.._ Submit evaluation lo the air
   quality division within your
 state's environmental agency.
                                                                                  3

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 Step 2:  Is Your Landfill Regulated bv the NSPS or EG?

 Once you have determined that your landfill is affected
 by the landfill rule, you must determine whether it is
 regulated by the New Source Performance Standards
 (NSPS) or Emission Guidelines (EG).  Table 2 lists
 several possible scenarios. Figure 2 can  help you
 determine whether your landfill is considered "new"
 (and thus regulated by the NSPS) or "existing"
 (regulated by the EG) under the landfill rule.

 "New landfills" are those that began construction or
 acceptance of wastes for the first time on or after
 May 30, 1991 or that made a modification since
 May 30, 1991 that will increase overall emissions. New
 landfills are regulated under NSPS and should have submitted
 initial design  capacity reports by June 10,  1996.

 "Existing landfills" are those that were active  on or after
 November 8, 1987 and did not have a design capacity permit
 modification, or other modification that affects overall
 emissions, dated since May 30, 1991. Existing landfills are
 regulated by  the EG, and do not have to submit initial design
 reports until their state develops a plan that is approved by
 EPA.

The compliance requirements for the NSPS and the EG are
 basically the  same unless a given state decides to alter its
state rule from the EG.  Each state should have an approved
 EG by April 12,  1997.  Because NSPS is administered by
 EPA, whereas EG is implemented by the states, the  beginning
dates for compliance will be different for NSPS and EG
 landfills.  Section 4.0 provides information regarding
compliance timelines.
The dates that are
important in determining
whether the landfill is
affected by the landfill
rule are the date the
landfill commenced
construction and the
dates the landfill has
actively accepted waste.
                          TABLE 2. APPLICABILITY EXAMPLES
 Scenario
              Regulation
 Landfill closed prior-^o-November-8,  1987

 Landfill closed between November 8, 1987 and May 30,  1991

 Landfill active with design capacity permit issued before May 30, 1991

 Landfill active with design capacity permit modification issued after
 May 30.  1991

 Landfill accepts first waste after May 30, 1991
                Exempt
                  EG
                  EG
                NSPS

                NSPS

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                                      FIGURE 2
                  DETERMINING IF YOUR LANDFILL IS REGULATED
                                UNDER NSPS OR EG
                  Landfill active on or after
                    Novembers, 1987?
                       Yes
                    Was landfill closed
               between November 8,1987 and
                     May 30,1991?
                        No
                  Was landfill active before
                      May 30,1991
                    with no modification
                    since May 30,1991?
                       No
       Landfill not regulated under
             landfill rule.
Yes
Yes
                   Landfill regulated under
              New Source Performance Standards
                        (NSPS)
 Landfill
regulated
  under
Emissions
Guidelines
  (EG)
Step 3;  Does Your Landfill Meet the Design Capacity
Threshold?

After you have determined whether your landfill is
regulated by the NSPS or EG, the next step in
determining if your landfill is  affected by the landfill rule
is to evaluate the landfill's design capacity. If the total
permitted capacity is below 2.5 million Mg of waste
(2.75 million tons) or 2.5 million cubic meters (3.27
million cubic yards),  the landfill is exempt from further
evaluation, and you need only submit a design capacity
report to the air quality division within your state's
environmental agency.

All landfill cells wust-be converted-to the same-units.
If, for example, one cell was  permitted in tons and an
active cell was permitted for cubic yards,  convert both
cells to the same units and add them together. An
amended design capacity report and an emissions
report will be required if the design capacity of the
landfill is expanded to above  2.5  million Mg.
                  What is a megagram
                  (Mg} or cubic meter?

                    -   1 Mg = 1.10
                        tons

                    •   1 cubic meter **
                        1.31 cubic yards.

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 Step 4:  What are Your Landfill's Annual NMOC
 Emissions?
If your landfill is above the design capacity threshold,
you must determine the landfill's annual emissions of
non-methane organic compounds (NMOCs).  The test
methods and procedures to determine NMOC emissions
are found in  §60.754 of the landfill rule.  EPA has
developed the Landfill Air Emissions Estimation Model
(LAEEM) to help landfill owners calculate their NMOC
emissions.

The LAEEM model requires basic information about a
landfill-e.g.,  size, age, and annual waste accepting
rate-to calculate annual NMOC emissions.  If a
landfill's NMOC emissions are greater than or equal to
50  Mg/year,  the landfill rule requires the installation of a
gas collection and control system.1

In addition to basic inputs related to the landfill's
operating information, the LAEEM model also allows
landfill owners to input site-specific values for their
landfill's NMOC concentration. It is  important to note
that the default NMOC concentration provided in the
landfill rule is conservative.  Therefore,  the landfill rule
allows landfill owners to test for site-specific NMOC
concentration and enter it into the model.2 If site
testing reveals lower NMOC concentration, the
resultant annual NMOC emissions that are calculated
from this input value will be lower.
If you plan to do the
reports and calculations
yourself, it is important
to obtain a copy of
EPA's LandfiliAir
Emission Estimation
Model.  It may be
downloaded from the
OAQPS-TNN Bulletin
Board by dialing (919)
541-5742.
     The scope of this booklet does not cover system
     design.  Make sure the system is designed to address
     the specifics of your site; a system designed for a
     nearby landfill may not be the most effective design for
     your site. For more information on system design, you
     should consult the "Enabling Document for the New
     Source Performance Standards and Emission Guidelines
     for Municipal Solid Waste Landfills," developed by U.S.
     EPA, No. EPA-_45a/Rr9 6-004. -This document is
     available free of charge through EPA's Technology
     Transfer Network Bulletin Board System under the
     Clean  Air Act Amendment Technical Information area.

     This is known as "Tier 2" calculation. By replacing the
     default NMOC concentration with a site-specific  value,
     the landfill's estimated NMOC emissions may fall below
     50 Mg/year and thus exempt the landfill from the
     requirement to install a gas collection  and control
     system.

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 If, after running your landfill's inputs through the LAEEM
 model, your landfill's NMOC emissions are greater than
 or equal to 50 Mg/yr, the landfill rule allows you to sub-
 stitute a site-specific gas generation rate for the default
 value to calculate NMOC emissions (this is known as
 Tier 3 Analysis}.3

 However, testing for the site-specific gas generation rate
 is far more costly than testing site-specific NMOC con-
 centration during Tier 2 analysis.  Therefore, it may not
 be cost-effective to undertake Tier 3 testing.

 Sample report forms for the design capacity report and
 the emission calculation reports are provided in the
 landfill rule Enabling Document.
SECTION 3.0
MEETING THE REQUIREMENTS OF THE
LANDFILL RULE
Figure 3 (see next page) outlines the requirements for
compliance with the landfill rule.  The five main
requirements for complying with the rule are:

   •     Submitting compliance reports,

   •     Installing a gas collection system,

   •     Destroying the LFG at 98 percent efficiency,

   •     Adhering to specified operation and
         maintenance procedures, and

   •     Following specific recordkeeping and reporting
         requirements.

 Each of these is discussed in the following sections.

Step 1:  Submitting Compliance Reports

As mentioned previously, if a landfill's design capacity is
below 2.5 million Mg oj: its annual NMOC emissions are
below 50 Mg, the landfill owner is only required to  sub-
mit a  design capacity report to the State air agency.  If
the design capacity is at or above 2.5 million Mg, the
landfill must submit annual emission reports until
emissions exceed 50 Mg/yr or the landfill closes.
LandfiHs that are
affected by NSPS were
required to submit
reports as early as
June 10, 1996.
Compliance schedules
for landfills regulated by
EG depend on the date
that the State Flan for
implementing EG
requirements is
approved by the
Administrator.
     By replacing the default gas generation rate with a
     measured site-specific value, the landfill's estimated
     NMOC emissions may fall below 50 Mg/year and thus
     exempt the landfill from the requirement to install a gas
     collection and control system.

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               FIGURE 3.  THE  LANDFILL RULE COMPLIANCE REQUIREMENTS
                                             MSW Landfill
                           <2.5
                         million Mg.
     Submit
    amended
     design
     capacity
                                               Design
                                               Capacity
                           2 2.5 million Mg.
                               Submit design
                              capacity report to
                              State Air Agency
                                          NMOC < 50 Mg/yr.
                           Determine
                         Annual NMOC
                           emissions
                 NMOC > 50
                   Mg/yr.
                   Submit design
                      capacity
                      report to
                      State Air
                      Agency.
    Submit annual
      emissions
     reports until
      emissions
       exceed
     50 Mg/yr or
      the landfill
       closes.
              Install gas
              collection &
            control system.
                       Destroy
                    landfill gas at
                        98%
                      efficiency.
   Operate system
   for minimum of
 15 yrs.  System must
remain in operation until
 landfill has dosed, and
  annual NMOC rate
  falls below 50 Mg.
 Submit annual report
outlining the following:
  - downtime
  - sytem failure
  - locations of surface
   monitoring exceedances, and
  - locations of new wells or
   equipment installed.
8

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 If you plan to test your landfill's NMOC concentration or
 gas generation rate (e.g., perform a Tier 2 or Tier 3
 analysis), you should begin this process as early as
 possible to provide sufficient time to evaluate
 emissions, submit reports, and design the gas
 mitigation system, if necessary.

 Step  2:  installing a Gas Collection System

 A typical landfill gas collection system consists of:

  • Vertical extraction wells,
  • A header system,
  • A blower,
  • Water (or condensate) knockout equipment, and
  • An energy-producing combustion device or gas flare.

 Figure 4 shows a typical gas extraction well. The
 extraction wells generally are drilled to approximately
 75 percent of the refuse depth. The header system is a
 network of pipes that ties the wells together.  The
 blower extracts gas from the wells through the header
 system to either a flare that burns the gas or to an
 energy-producing combustion device (such as internal
 combustion engines or gas turbines).  Because LFG
 moisture content is much greater than natural gas,
 condensate traps are  important to remove condensate
 that collects  in the system.  Figure 5 depicts the major
 components  of a collection and control system.  It is
 important to  note that LFG mitigation systems generally
 are tailored to site-specific details. For example, if you
 plan to install future cells on top of existing cells,
 horizontal collectors could be placed  so that the
 controls are outside of the refuse. This allows system
 monitoring and wellhead adjustment to continue even
though refuse is placed on top  of extraction wells.
Additionally,  surface extraction wells should be used if
the landfill's water level is very high. Vertical wells are
more  effective in deep (over 40 feet) refuse with a low
water level.  Installing a synthetic cover reduces cover
maintenance, the number of wells required, and the
surface monitoring frequency.  Professional engineers
must  certify the  design of the LFG collection system.
Qualified engineers can help owners/operators reduce
costs and insure system reliability.
If a landfill owner intends
to put in a gas collection
and control system, the
design phase may be
commenced at any time
and the landfill does not
need to test the gas
concentration or flow rate.
However, knowledge of the
gas concentration and
expected flow rate
provides more information
to the engineers designing
the system; therefore, early
tests could save the landfill
owner money in the long

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              FIGURE 4. SCHEMATIC OF A TYPICAL GAS EXTRACTION WELL
                                            VALVE
                  SPECIAL BACWIU.-
                                     BOTTOM Of
                                      TRASH"
                                                             VARIES
             FIGURE 5.  SCHEMATIC OF A TYPICAL LFG COLLECTION SYSTEM
                                                                       BLOWER /FLARE
                                                                         STATION
10

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 Step 3:  Destroying LFG at 98 Percent Efficiency

 Under the landfill rule, the gas collection and control
 system constructed is required to destroy the landfill
 gas at an efficiency of 98 percent.  The landfill rule also
 requires surface monitoring to evaluate collection
 system efficiency.  The two principal LFG destruction
 methods are LFG energy recovery and flaring. LFG-to-
 energy should be evaluated at each landfill site to
 determine whether it is cost-effective, as it offers
 landfill owners an opportunity to mitigate the costs of
 compliance with the landfill rule.  As with the collection
 system design, the LFG destruction/control device
 should be chosen with the landfill's specific
 characteristics in mind. See Section 5.0 to learn how
 to evaluate  LFG-to-energy at your landfill.

 If energy recovery is not an option, the other acceptable
 LFG destruction method is to flare the gas. Both open
 and enclosed flares are acceptable; however, open
 flares have the following disadvantages: less efficient
 combustion, aesthetic complaints, and the difficulty of
 testing emissions. Enclosed flares, on the other  hand,
 while being  more expensive, tend to be more reliable
 and efficient because the landfill operator can adjust
 the air flow  to reduce unburned hydrocarbon and other
 volatile emissions.

 Step 4:  Adhering to Operation/Maintenance Procedures

 Compliance with the landfill rule extends beyond the
 installation of a gas collection  and control system.
 Once the gas collection system is operational, it  can be
 shut down only if it has been running at least 15 years,
 the landfill is closed and the annual NMOC emission
 rate is less than 50 Mg.  Note that all three conditions
 must be  satisfied before a gas collection system  can be
 shut down under the landfill rule.

Each-LFG well head ortrencti must be monitored t>n a
monthly  basis for pressure, temperature, and  gas
quality (i.e., concentrations of methane, nitrogen, and
oxygen). The operator must also ensure that the
system is operating with a vacuum at each extraction
point and is  operating with minimal air infiltration.  In
 Note that the rute does
 not require minimum
 efficiency for the
 collection system, as it
 is difficult, if not
 impossible, to measure.
See the full text of the
LF rule for exact
specifications for system
monitoring (40 CFR Part
60.755),  This text is
available free of charge
through EPA's
Technology Transfer
Network Bulletin Board
System under the Clean
Air .Act Amendment
Technical Information
area.
                                                                                 11

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 addition, the operator must monitor the landfill surface
 regularly to ensure that the methane concentration is
 less than 500 ppm above background at the surface of
 the landfill. Both the well monitoring and surface
 monitoring require certain procedures to correct any
 unacceptable emissions rates.  Such procedures may
 include wellfield or wellhead adjustments, and/or the
 installation of additional extraction points.

 Step 5: Following  Recordkeeping and Reporting
 Requirements

 The  landfill rule contains specific recordkeeping and
 reporting requirements, including the type of
 information that must be recorded from the landfill's
 monitoring program.  The landfill operator must submit
 an annual report outlining downtime, system failure,
 locations of surface monitoring exceedances, and
 locations of new wells or equipment installed.  Reports
 must be kept in accessible files. Consult the rule in the
40 CFR Parts 60.756 and 60.757 for more information
 on recordkeeping and reporting requirements.

SECTION 4.0   MEETING THE DEADLINES

A timeline for compliance was established for NSPS
landfills based on the March 12, 1996 publication date
of the final landfill  rule.  Table 3 lists the important
compliance dates for the NSPS.  Existing landfills can
wait until a timeline is established by their state.
However, because it will take approximately one year
for states to establish their plans, EG landfill owners
can add one year to the following dates to get a rough
estimate of what their EG compliance dates might be.
    TABLE 3. COMPLIANCE DATES FOR AN NSPS LANDFILL
 REPORT/ACTIVITY                           DUE DATE

 Design capacity and NMOC emission report        06/10/96

 NMOC report with gas concentration test(optional)   12/07/96

 NMOC report with gas generation rate test         06/10/97
 (optional)

 Design plans for collection and control system      06/10/97

 System installation                           12/10/98

 Performance test/1 st annual report               06/10/99
The Annual Report must
outline the following:

•   Downtime;

•   System Failure;

*   Location of surface
    monitoring
    exceedances; and

•   Location of new
    wells or equipment
    Installed.
12

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 SECTION 5.0
EVALUATING LFG-TO-ENERGY
OPTIONS
 Step 1:  Technical Overview

 As discussed in Section 4, the landfill rule requires that
 collection systems convey LFG to a control device that
 is capable of destroying 98 percent of NMOC's found in
 LFG. While landfill owners need only install a flare to
 comply with the landfill rule, they should investigate the
 options for energy recovery wherever possible.  The
 Landfill Methane Outreach Program has developed the
 Project Development Handbook specifically to help
 landfill owner/operators evaluate whether gas-to-energy
 is an attractive option for their landfill.

 Because the LFG is 50 percent methane-a valuable
 source of energy-collected landfill  gas may be
 harnessed for fuel, which can be sold to mitigate the
 cost of installing the collection system and can even
 generate a profit. The most common energy recovery
 options are local gas use, electricity generation, and
 pipeline injection.

 Assessment of the requirements for energy at the site
 and in the surrounding  area, and evaluation of the
 project economics help to determine the appropriate
 option for a specific landfill. Additional information
 regarding the main energy recovery options is provided
 below.

 Local Gas Use. Local gas use is the simplest and  most
 cost-effective option for using the recovered gas.
 Medium-Btu LFG is delivered via  pipeline from the
 landfill to nearby equipment, such as boilers and
 engines.  Prior to transporting LFG to a user,
 condensate and particulates must be removed through a
 series of filters  and/or driers to clean and upgrade  the
 LFG to a minimum of 35 percent methane. The
 feasibility of this-option is generally determined by the
 distance  needed to transport the gas to a potential end
 user.  In general, distances up to 5 miles are feasible.
 If local gas use  appears favorable, the first step is to
contact potential end users to determine their interest.
                                          The LMOP's Protect
                                          Development Handbook
                                          contains detailed infor-
                                          mation on LFG-to-energy
                                          technology options and
                                          costs, assessing project
                                          economics,  identifying
                                          services, and obtaining a
                                          permit, among other
                                          things, and can be
                                          obtained by calling t-
                                          888-STAR-YES (toll
                                          free).
                                                                                13

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 Electricity Generation.  LFG also can be used to
 generate electricity for on-site use or for distribution
 through the local electric power grid.  The two most
 commonly used technologies for generating electricity
 are internal combustion (1C) engines and gas turbines.

 1C engines are stationary engines, similar to
 conventional automobile engines, that can use medium-
 quality gas to generate electricity.  An advantage of 1C
 engines is that a number of them may be utilized at the
 start of a recovery project and phased out or moved to
 alternative utilization sites as gas production decreases.
 1C engines can also be  easily turned on and off and are
 therefore suitable for supplying intermittent power
 needs. This flexibility makes 1C engines a more
 attractive option for smaller landfills. One disadvantage
 of 1C engines  is that they have higher emissions of
 nitrogen oxide (NOx)  than gas turbines.

 Gas turbines typically require higher gas flows and are
 therefore more suitable at large landfills.  Because gas
 turbines must run constantly, they are used to generate
 electricity that will be distributed through the electric
 power grid on a continuous basis.  Gas turbines are
 relatively compact, have low operations and
 maintenance costs, and have lower emissions of NOx
 than 1C engines.

 Emerging technologies for electricity generation, such
 as steam turbines and fuel cells, are being tested for
 use with LFG.  In addition, some landfills are beginning
 to use landfill  gas as  a vehicle fuel, where they convert
 the LFG into liquified  natural gas, compressed natural
 gas, or methane.  Steam turbines consist of a
 conventional gas/liquid  fuel boiler and a generator that
 produces electricity.  They are currently only used at
 very large landfills—i.e., those where gas flows are
 greater than five million cubic feet per day (MMcfd).

 Fuel cells create energy by combining the hydrogen
 found in LFG with oxygen in an electrochemical
reaction. Their modularity, small capacity, high
 efficiency, quiet operation, and  low environmental
 impact may make them the ideal technology for power
 generation with LFG. However, fuel cells are not as
 cost-effective as the  other energy recovery options.
 Gas-to-Energy Case Study

Puente HHIs Landfill.
Whfttfer. California

Puente HHIs is the largest
landfill energy recovery
power project in the United
States.  It has been opera-
tional since the early
1980s.

The landfill  receives
12,500 tons of waste per
day,  and collects over 30
MMcfd from 400 vertical
wells and 50 mites of
horizontal collection piping.

The Los Angeles County
Sanitation District, which
operates the landfill, uses
the landfill gas in three
ways:

  »    to generate almost
       50 MW of power m
       a boiler/steam tur-
       bine configuration,
       located at the
       landfill;

  •    as vehicle fuel, in
       the form of
       compressed natural
       gas;

  •    as fuel for a boiler
       at Rio Hondo
       College, Jocated
       one-mile away.
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 Upgrade to High-Btu Gas. If a pipeline carrying
 medium- or high-quality gas is nearby and there is no
 local gas user available, pipeline injection may be an
 attractive option. To assess the feasibility of pipeline
 injection, the proximity, capacity, and gas quality
 specifications of the pipeline should be determined.
 Upgrade to high-Btu gas also  requires treatment  of the
 LFG to remove carbon dioxide and other impurities. As
 a result, this option is more expensive than local gas
 use or electricity generation.

 Step 2:  Making The Economics Work

 EPA estimates that over 700  landfills in the U.S. can
 cost-effectively install LFG energy recovery systems.
 Only about  140 projects in the U.S. are currently
 converting LFG into energy.  With the landfill rule in
 place, many more projects will come online in the next
 few years.  Each landfill owner needs to assess
 whether they can make the economics work at their
 landfill.  Assessing project economics  involves
 estimating the costs and revenues, developing a  cash
 flow model, and obtaining appropriate financing.

 Gas Utilization Costs.  Gas or electricity sales offset the
 total expense of a gas collection system and energy
 recovery equipment. If your landfill is required under
 the landfill  rule to install a gas collection and control
 system, you should consider the expenditure as a sunk
 cost. Costs of recovering and using LFG are dependent
 on the amount of gas involved and the energy recovery
 technology used.

 Energy Sales Revenues. Depending upon the type of
 energy produced, a landfill owner may realize one of
 several  revenue streams, as seen in Table 4.

 Financing Approaches.  There are several sources of
 capital for landfill gas-to-energy projects, including
 private equity financing, project financing,  municipal
 bonds, or direct municipal funds. In addition, EPA is
 working  with utilities and states to develop innovative
and alternative financing mechanisms.
 Gas-to-Energy Case Study

The Battteboro Landfill
Vermont

This is one of the oldest
landfill gas recovery
projects in the country.
When energy recovery
began in 1983, the landfill
contained Jess than 1
milfion tons of waste. The
approximately 11,000
cubic meters of gas
collected per day in the
landfill are used in 1C
engines to generate less
than 1 MW of electricity,
which is sold to the local
utility.
The LMOP has developed
*E-Plus" software which
helps landfill owners
assess the economic   ,
potential of various LFG-to-
energy options at their
landfill. To order this
software, call toll free 1-
888-STAR-YES
II -888-782-7937)
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TABLE 4. ENERGY RECOVERY COST COMPARISON
Energy Recovery
Option
Local Gas Use
Electricity Generation
Pipeline Injection
Equipment
Gas Utilization Equipment
(boilers, engines, etc.)
Pipeline
Operation & Maintenance
(O&M)
1C Engines (including
auxiliary equipment,
interconnections, gas
compressor, construction,
and engineering)
Gas Turbines (including
auxiliary equipment,
interconnections, gas
compressor, construction,
and engineering)
Operating Costs
Pipeline Construction
Gas Cleaning and
Compression Equipment
Operating Costs
Approximate Price
$ 120,000 for 10,000 Ib/hr
boiler to $300,000 for an
80,000 Ib/hr boiler
$100,000 -$200,000 per
kilometer
Similar to O&M costs
associated with using
conventional fuels
$900 to $1,200 per net k;W
output
$ 1 , 1 00 to $ 1 ,300 per net kW
output (for landfills with less
than 5 million tons waste in
place)
$0.01 to $0.025 per kWh of
electricity produced
$100.000 -$200,000 per
kilometer
$25,000 per rrrVminute of
gas flow (assuming LFG is 50
percent methane)
$600 per hp (for compression
costs - 7.2 hp/m3/min is
required to compress the gas
to lOOpsi)
Potential Revenues
The savings that are
achieved by
offsetting energy
purchases.
Typical gas price: $2
- $5 per MMBtu
Electric Buyback
Rate: $0.02/kWh to
$0.06/kWh
Displacement of On-
Site Energy
Purchases
Thermal Energy
Revenues:
$1.5/MMBtuto
$6/MMBtu for steam
Tax Credits/Subsidies
Local distribution
companies will
purchase processed
LFG for same price as
natural gas.
Typical gas price:
$1.5 to $3.0 per
MMBtu
Sources:  U.S. EPA (1995), Turning a Liability into an Asset: A Landfill Gas-to-Energy Project Development
          Handbook, Atmospheric Pollution Prevention Division, Office of Air and Radiation, Washington, DC,
          1995.

          U.S. EPA (1996), A Guide for Methane Migration Projects, Gas-to-Energy at Landfills and Open
          Dumps, Atmospheric Pollution Prevention Division, Office of Air and Radiation, Washington, DC,
          1996.
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 Private Equity Financing - Private equity financing
 involves an investor who is willing to fund part or
 all of the landfill gas-to-energy project in return for
 a significant share of project ownership.  Potential
 equity investors include equipment vendors, fuel
 suppliers, and industrial companies.  Landfill
 owners should keep in  mind that equity investors
 will likely expect to receive benefits-such as
 equipment sales, service contracts, or energy
 supplies—in addition to  a portion of the project's
 cash flow.

 Project Finance - Project finance is a method for
 obtaining commercial debt financing where lenders
 look to a project's projected revenue stream rather
 than the assets of the developer/sponsor to ensure
 repayment. The biggest advantage of project
 finance is the ability to  use others' funds for
 financing without giving up ownership control.
 The best opportunities for landfill gas projects to
 secure project financing are generally with the
 project finance groups at smaller investment
 capital companies, banks, and law firms, or at one
 of several energy investment funds.  The primary
 disadvantages of project finance are the high
 transaction costs and lender's high minimum
 threshold for investment.

 Municipal Bond Financing - Municipally owned
 landfills occasionally issue tax-preferred municipal
 bonds to finance gas-to-energy projects.  The
 biggest benefits of using this financing method are
 that it is the most cost-effective financing method-
 -the resulting debt has an interest rate that is
 often 1 to 2 percent below commercial debt--and
 the debt repayment can be extended over the life
 of the facility (typically  20  or more years). Terms
 for securing municipal bond financing vary
 according to the type  of bond, method of
 qualification and the state or municipality in which
the bond is issued.  The primary disadvantage of
municipal bond funding  is the barriers faced by
municipalities in issuing  bonds.
Assess Project
Economics

•   Cost Analysis:
    develop estimates
    for capita! costs,
    operations and
    maintenance
    expenses,

-•   Benefits Analysis:
    compare revenues
    generated, emissions
    avoided.

•   Create an analysis of
    cash flows.

•   Compare project
    costs and benefits to
    assess economic
    feasibility.

•   Compare options.
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  •  Direct Municipal Funding - Landfill gas energy
     projects can also be funded directly through the
     operating budget of a city, county, landfill
     authority, or other municipal government.  The
     advantages of this financing method are that it
     eliminates interest charges on project debt and has
     less lender due diligence requirements; the
     disadvantage is that municipalities may face
     difficulties raising revenues.

  •   Other Potions - The LMOP is  also working with its
     State and Utility Allies to develop sources of
     financing for LFG-to-energy projects. For example,
     the LMOP is currently investigating the feasibility
     of state-sponsored revolving funds for landfill gas-
     to-energy projects.  These funds could  be
     capitalized through the issuance of tax-exempt
     bonds and would offer low interest loans to landfill
     owners looking to finance landfill gas collection
     and energy recovery systems. The fund would
     "revolve," that is, continue to supply financing to
     new landfill gas projects as previous projects make
     good on their loans.

Tax Credits and Incentives.  Tax credits and federal
incentive payments can significantly improve project
economics.  Currently, Section 29  of the Internal
Revenue Code offers tax credits for the recovery and
use of landfill gas.  Additionally, the U.S. Department of
Energy's Renewable Energy Production Incentive (REPI)
program provides an incentive to publicly-owned
facilities that generate electricity from renewable
energy sources (including landfill gas.)

  •   Section 29 - The Section 29 tax credit  is available
     to landfill gas projects that have their collection
     system  installed and in operation by July 1, 1998.
     The tax credits apply only to landfill gas that is
     produced and then sold to an  unrelated third party.
     In order to take advantage of  Section 29 credits,
     project developers may create a separate
     company, or bring in another party.  The current
     value of the credit is $1.005 per MMBtu.
Examples of Capital
Cost Elements

»   LFG Equipment
«   Construction
    - WellfieJd
    - Blower Station
    - Other Construction
•*   Emissions Controls
«   Interconnections
«   Gas Compression
    and Treatment

«   Engineering
*   Soft Costs
Currently, Section 29 tax
credits are only available to
projects that signed a gas
rights contract by
December 31,1996, and
that actually install an
operational collection
system by June 30, 1998.
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  •  REPI - Section 1 212 of the Energy Policy Act of
     1992 provides a subsidy of 1.5 cents per kilowatt
     hour to renewable energy electrical power projects
     owned by a state or local government or nonprofit
     electric cooperative.  NOTE:  The availability of
     funding for REPI payments is subject to annual
     appropriation  by Congress.

SECTION 6.0   U.S. EPA LANDFILL METHANE
               OUTREACH PROGRAM RESOURCES

A key objective of the Landfill Methane Outreach
Program (LMOP) is to provide landfill owners and
operators, developers of landfill gas-to-energy projects,
utilities, and other potential project participants with                       	
information to increase awareness of project                LANDFILL METHANE
opportunities and enhance  understanding of the energy,      OLTTREACH PROGRAM
environmental, and economic benefits of landfill energy
recovery. Various technical outreach materials have
been developed to overcome informational barriers to
the development of energy recovery projects.

Contact the LMOP  Hotline or utilize the LMOP Home
Page to request outreach materials or to obtain more
information.  Information currently available through
LMOP includes:

  • .  Fact Sheets

        Utility Ally Program
        Industry Ally Program
        Landfill Gas Direct Use

  •   Documents

        Landfill Gas-to-Energy Project Development
        Handbook

        Landfill Gas Energy Recovery Financing
        Workshop Proceedings

    -   Profiles of Candidate Landfills for Selected
       States

 •  Software

        Landfill  Gas Energy Recovery Project
        Evaluation Software (E-Plus)
                                                                              19

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 For more information, contact:

     EPA Landfill Methane Outreach Prograrn
     U.S. EPA, 401 M Street, SW,
     Mail Stop 6202J
     Washington, DC 20460

     Hotline: 888-STAR-YES (1-888-782-7937)
     Fax: (703) 934-3895

     Internet Home Page:
     http://www.epa.gov/lmop.html
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