LMOP Quick Reference Sheet:
Regulations and Proposals Affecting
Landfills and LFG Energy Projects
LANDFILL METHANE
OUTREACH PROGRAM
May 2011
GHG Reporting Rule (final rule published 10/30/09) -
MSW landfills are required to report if annual CH4 generation > 25,000 metric tons CO2e.
Subject landfills would report CH4 generation and emissions, at a minimum.
For the final rule, a landfill information sheet, FAQs, and an applicability tool:
http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.
GHG Endangerment Finding (published 12/15/09)-
EPA determined that the current and projected concentrations of the six key well-mixed
GHGs, including CH4, in the atmosphere threaten the public health and welfare of current
and future generations. For the full findings, background information, and other resources:
http://www.epa.gov/climatechange/endangerment.html.
PSD and Title V GHG Tailoring Rule (final rule published 6/3/10) -
Set thresholds for GHG emissions that define when CAA permits under Title V and NSR
permit programs would be required. There are two initial phases:
Step 1 (Jan '11 - Jun '11): no sources would be subject due solely to emissions of regulated
GHGs, rather something else would trigger the new requirements.
• PSD sources already subject: net GHG emissions increase of > 75,000 tons CO2e.
• Title V sources already subject: when applying for, renewing, or revising permit.
Step 2 (Jul '11 - Jun '13): regulated GHGs do affect applicability.
PSD sources: > 100,000 tons/yr CO2e for New;
increase of > 75,000 tons/yr CO2e for Existing.
Title V sources: > 100,000 tons/yr CO2e.
Biogenic CO2 was not exempted in the promulgated rule, however, on March 21, 2011,
EPA proposed a three-year deferral of CO2 emissions from biogenic sources.
For the rule, proposed deferral, guidance document, and other information:
http://www.epa.gov/nsr/ghgpermitting.html.
Internal Combustion Engines NESHAP (final rules published8/20/10,3/9/11) -
Implemented emission standards, monitoring, recordkeeping, and reporting requirements
for LFG-fired internal combustion engines at major and area sources of HAP.
Existing, non-emergency, spark ignition, LFG-fired engines:
• > 100 HP and < 500 HP at major sources: limit of 177 ppmvd CO at 15% O2.
• any size at area sources: management practice standards in lieu of a CO limit.
Previous rules in 2004 and 2008 set standards for other LFG-fired engines. For the final rules
and other information: http://www.epa.gov/ttn/atw/rice/ricepg.html. J
-------
' Major Source Boiler and Process Heater NESHAP (final rule published 3/21/i i;
notice of reconsideration 3/21/11; stay to delay effective date of rule 5/18/11) -
EPA is reconsidering this standard and has issued a stay to delay its effective date, allowing
additional time to review public comments and input submitted on the rule. Owners/
operators of LFG-fired boilers/process heaters at major sources can submit additional data
and information about their sources and emissions for EPA's consideration by July 15, 2011.
Per the 3/21/11 rule, LFG-fired units that operate no more than 876 hr/yr, have a design heat input
capacity < 10 MMBtu/hr, or fire a gas stream that either meets a minimum CH4 content or heating
value or does not exceed maximum Hg or H2S concentrations will be subject to tune-up work
practices. The rule also exempts a unit used as a control device to comply with another MACT
standard if > 50% of its heat input is from the gas stream regulated under that standard. Units not
meeting the above criteria would be subject to emission limits for PM, HCI, Hg, CO, and dioxin/furan.
For the final rule, notice of reconsideration, and other information:
http://www.epa.gov/ttn/atw/boiler/boilerpg.html.
NSPS and EG for MSW Landfills (final rule published 3/12/96) -
Landfills that are greater than or equal to 2.5 million Mg and 2.5 million cubic meters in
design capacity and have estimated emissions of non-methane organic compounds
(NMOCs) of at least 50 Mg peryear must reduce their emissions of LFG. For landfills that
commenced construction, reconstruction, or modification on or after May 30, 1991, the
NSPS apply. For older landfills that received waste after Novembers, 1987, the EG apply.
For the final rule and other information: http://www.epa.gov/ttn/atw/landfill/landflpg.html.
Amendments have been proposed but are not yet final. J
NESHAP for MSW Landfills (final rule published 1/16/03) -
Landfills with design capacities of at least 2.5 million Mg and 2.5 million cubic meters and
estimated uncontrolled emissions of NMOCs of at least 50 Mg per year are required to
collect and treat or control emissions of LFG. Subject landfills that operate part or all of
the landfill as a bioreactor must install collection and control systems for the bioreactor
earlier than would be required by the NSPS. The NESHAP also require semi-annual
compliance reporting, instead of the annual reporting required by the NSPS.
For the final rule and other information: http://www.epa.gov/ttn/atw/landfill/lndfillpg.html.
For More Information:
EPA Climate Change site
http://www.epa.gov/climatechange/
LAAOP LFG Energy Project Development Handbook, Chapter 5.
Landfill Gas Contracts and Permitting
http://www.epa.gov/lmop/documents/pdfs/pdh_chapter5.pdf
Clean Air Act
http://www.epa.gov/lawsregs/laws/caa.html
EPA Rulemaking Gateway
http://yosemite.epa.gov/opei/RuleGate.nsf/
------- |