At first glance, deciphering the new federal landfill gas regulations may appear as noxious and as nebulous as the emissions they were created to control.
Acronyms like NSPS, NMOC, EG and LFG are as prolific as the number of questions they raise. They can trick landfill operators into thinking they're wading through alphabet soup rather than preparing to implement guidelines on how to better manage and monitor their facilities' emissions.
Since being published in March 1996, the U.S. Environmental Pro-tection Agency's (EPA) methane regulations have prompted landfill owners to ask many questions. In the process, they are learning to become technically and financially creative in order to meet the challenges ahead.
The Time Has Arrived "Until now, landfill operators haven't had to collect and combust methane gas unless their facilities had migration or odor problems," said Mike McGuigan, project advisor, SCS Engineers, Reston, Va. "But landfills are responsible for one-third of all man-made methane gas sources. So, obviously, the EPA recognized the need to create the new regulations if we are to reduce global emissions."
Most solid waste experts agree that regulations were necessary, but the litmus test on their appropriateness is just beginning. "Major trade organizations generally support the control of methane from large landfills," Mc-Guigan conceded. "The level of specific procedures and reporting requirements, however, are greater than industry standards and will place significantly larger burdens on landfill owners."
Phil Carter, president of the North Carolina Chapter of the Solid Waste Association of North America (SWANA), Silver Spring, Md., agrees.
"Even though they're still a little rough around the edges, the regulations are vital and necessary to deal with a problem that, in the past, hasn't been addressed on a wide scale," Carter said.
"North Carolina landfill owners have been monitoring methane since 1993," he continued, "so everyone is familiar with the reporting requirements. Now, we're waiting to see if we'll have to install collection systems."
Do The Regs Affect Me? The first step in determining whether the new regulations affect your landfill is to apply three criteria: dates of operation; permitted size; and non-methane organic compounds (NMOCs) emission levels.
Dates of operation are important. If your landfill closed prior to the passage of Subtitle D (November 8, 1987), your facility is exempt. However, many landfills operating past the regulatory deadline will fall into either New Source Performance Standards (NSPS) for new landfills or Emission Guide-lines (EG) for existing landfills. "The requirements are very similar," Mc-Guigan explains. "The major difference is the compliance schedule."
An existing landfill is determined by whether it was:
* constructed, modified or reconstructed prior to May 30, 1991,
* received waste on or after November 8, 1987 or
* has additional capacity which maybe filled in the future.
"The standards for older landfills are more site-specific because the states have allowed more flexibility to deal with older sites," McGuigan said. "States are required to put together the implementation plans, and compliance generally runs about a year later than the regulatory requirements for new landfills."
According to EPA program manager Tom Kerr, "Existing landfills don't have to submit initial design reports until their state develops a plan that is approved by the EPA."
NSPS landfills are considered to be facilities that accepted their first waste loads after May 30, 1991 or are active facilities that received design capacity permit modifications after that same date.
Site-Specific Values Under the NSPS requirements, facility size is an important consideration, particularly for those landfills serving rural areas with low volumes.
"If your landfill has a design capacity of less than approximately 2.75 million tons, your facility is exempt from NSPS," McGuigan said.
Once your facility's design capacity has been determined, the next criteria to apply is determining your landfill's NMOCs. The EPA designed a model to help landfill owners compile basic information about their sites to determine their NMOC emissions: If a facility generates 50 megagrams or more each year, it must install a gas collection and control system. The EPA also has given landfill owners the latitude of incorporating site-specific values into their emission models.
"The rules were written conservatively with the mindset, 'Cast a big net and you'll catch everybody unless [landfill owners] perform additional work to test out [of complying],'" McGuigan said. "The [regulations'] base assumptions overestimate gas generation, and the real difference is going to be evident when comparing dry with wet landfills." For example, climate conditions are key components in methane gas generation, McGuigan said.
"The wetter the landfill, the higher the generation, however, landfill gas collection is more difficult. In a dry climate, a landfill will generate lower rates of methane over a longer period of time."
Tough Love Approach Although the new regulations appear to cover most of the facets associated with the installation of collection and control systems, one major pitfall awaits landfill owners.
"The biggest component is cost, especially for those closed landfill sites that must install a collection system with potentially no revenue stream," McGuigan said.
Capital costs associated with new collection systems are said to range from $300,000 to several million dollars. "And, operational costs can be anywhere from $30,000 a year to a couple hundred thousand. It's definitely a significant annual ex-pense to landfill owners," McGuigan said.
In devising the new regulations, the EPA made no provisions for funding. On the surface, it appears unreasonable, especially to owners of closed landfills. But, this may be a classic case of tough love.
"Technically, the regulations are onerous, but the biggest bone of contention is money," McGuigan said. "Owners will have a greater incentive to find economic uses for landfill gas at or near their landfill sites to reduce landfill gas compliance costs."
Landfill owners who must install collection systems will be required to operate them for at least 15 years.
"The theory is, if you put in a million dollar system, get as much bang for your buck as possible, even if your emissions are lower than the threshold," McGuigan quipped.
Carter's North Wake Landfill in Raleigh, N.C., is a prime example of this philosophy and demonstrates how local government continues to work with the private sector to solve universal problems.
When state regulators determined a recovery system was needed at the 120-acre facility, Wake County joined with a private company to collect and contain the gas, and to sell the gas to a pharmaceutical plant. "The system would have been an impact to us financially, but we contracted with a vendor to install the system for virtually nothing," Carter said. "In fact, not only did it save us money since we only had to pay for a temporary flare system, but we're saving the industry money to fire their boiler with our gas."
Help For Landfill Owners Landfill owners have been pushed and prodded to comply with a host of federal landfill regulations, but now they have an opportunity to participate in a program voluntarily that might actually make them money, and, in the process, make the new emission guidelines easier to implement.
Created in 1994 as a national initiative to the international problem of global warming, the EPA's Landfill Methane Out-reach Program (LMOP) is now maturing into a liaison between landfill owners and potential private users of methane gas.
"Our program doesn't require anybody to do anything," said LMOP's Tom Kerr. "It's strictly voluntary. What we're saying is, 'If it's a [gas] project at the landfill and it's good for the environment and you can make a profit or there's economic incentive in doing it, then [a gas program] makes sense.'"
The advent of the new regulations last year has put LMOP in the spotlight as the voice of authority concerning gas collection and combustion options for landfill owners. It offers a multitude of services with which landfill owners can determine their most cost-effective and realistic opportunities.
"We have a set of tools that can assess the options for landfill owners and help them to recognize whether our program can be an asset to them," Kerr said.
LMOP's Project Development Handbook is a 300-page "bible," providing landfill owners with all of the program possibilities, regulatory issues, legal considerations and economic factors to determine if a gas collection and combustion system is achievable.
In January, LMOP launched E-Plus, a new software that quickly determines whether a landfill gas system will be economically successful, based on landfill demographics and site specifics. "Landfill owners plug in the basic information about their facilities and the software generates everything from cash flow analysis, net present values and internal rates of return. Essentially, everything associated with making a decision about a gas collection system," Kerr said.
Landfill owners can call order the free handbook and software by calling the EPA's toll-free hotline: 1-888-*YES.
LMOP has developed partnerships with representatives from 63 industries, 13 utilities and 18 states. Its next venture is to promote these successes nationwide to initiate more partnerships.
Although Kerr admits LMOP's success has been hard to measure, EPA attributes 21 partnerships to the agency's assistance.
"Landfill owners and end-users don't normally make a practice of sitting down together in the same room and discussing landfill gas programs, but when the EPA facilitates the meetings, they're more likely to get together," Kerr said.
If you would like more information about LMOP, call (202) 233-9768.
Methane Gas, Part II will feature various applications of the requirements and the respective solutions.
* A-C Compressor Corp. Methane recovery systems. Contact: A-C, 401 East South Island St., Appleton, Wis. 54915. (414) 738-3088. Fax: (414) 738-5964.
* Fuller-Kovako Corp. Air, gas and vacuum rotary vane compressors. Contact: Anthony F. Dwyer, 3225 Schoenersville Rd., P.O. Box 805, Bethlehem, Pa. 18016-0805. (610) 264-6732. Fax: (610) 264-6711.
* Landfill Control Technologies. Landfill gas monitoring probes. Contact: Alex Roqueta, 6055 E. Washington Blvd., Commerce, Calif. 90040. (213) 722-8202. Fax: (213) 725-8772.
* Landfill Gas & Environmental Products Inc. Landfill gas, condensate and leachate control and recovery equipment. Contact: Ron Brookshire, 9855 Prospect Ave., Santee, Calif. 92071. (619) 596-9083. Fax: (619) 596-9088.
* Landfill Technologies Inc. Landfill gas systems and services. Contact: George Nealon, P.O. Box 519, West Sand Lake, N.Y. 12196. (518) 674-8694. Fax: (518) 674-8695. Reference: Chris Motyl, Town Of Rotterdam, 1100 Sunrise Blvd., Rotterdam, N.Y. 12308.
* Moretrench Environmental Services Inc. Landfill mining and reclamation. Contact: Carl Aspirinio, Moretrench, 7701 Interbay Blvd., Tampa, Fla. 33616. (813) 831-1871.
* Yesco Bva Cogen. Turnkey landfill gas developers. Contact: Yesco, 33 Christa McAuliffe Blvd., Plymouth, Mass. 02360. (508) 746-5500. Fax: (508) 746-1630.