For many landfill operators, trying to comply with both the new federal and state methane gas regulations can be a little like being a deer caught in the headlights: Getting to the other side of the road seems like a good idea, but the oncoming headlights can be confusing, at the very least.
By now, every operator should be aware of the U.S. Environmental Protection Agency's (EPA) new source performance standard (NSPS) under the Clean Air Act of March 12, 1996. In most cases, states have adopted the new federal regulations, but many of the timelines are different. To confuse matters further, most state environmental departments have made amendments to their respective air regulations pertaining to landfills.
The current challenge is not only complying with NSPS and state air regulation amendments, but also finding economically-feasible compliance solutions.
The first step, however, is understanding the new regulations, which are "fairly tricky," according to David Heitz, engineer-in-training for RUST Environment & Infrastructure Inc., Greenville, S.C. "There are some gray areas between state and federal emission guidelines," he says. "There have been some delays with many of the states. Some of the air bureaus were caught off guard, and it took them a little longer to get on line. This is the first major air regulation specifically addressing municipal solid waste landfills."
Indeed, across the country, state environmental regulatory agencies are scrambling to amend their respective air regulations, and as mentioned, many states are opting to adopt the full federal regulations as their own.
For example, Nebraska recently adopted the federal regulations. The majority of Nebraska landfills have submitted total design capacity reports to the state, and most of these facilities fall below the 10,000 mega gram (Mg) level and are exempt from further testing, notes Richard Webster, public information officer for the Nebraska Department of Environmental Quality in Lincoln.
Ohio's new regulations are being submitted for public comment this fall. The new rules, if adopted, will affect approximately 30 of the 70 landfills in the state, according to Heidi Griesmer, spokesperson for the Ohio Environmental Protection Agency in Columbus. Landfills emitting more than 50 tons of methane annually will have to install collection systems, she explains. Officials project all affected landfills must be in compliance within the next two-and-a-half years.
Other landfills are taking a "wait-and-see" approach to the new state and federal regulations, delaying action until the states have caught up to EPA, reports Heitz. Instead, he advises against this course, suggesting that each facility abide by the timelines established by the federal rules if the state rules have not been implemented.
The new federal regulations require that all landfills that began construction, modification or reconstruction, or began accepting waste on or after May 30, 1991 are subject to NSPS, and that any facility equal to or greater than 2.5 million Mg (or cubic meters) in design capacity is required to obtain a Part 70 (Title V) operating permit.
Dollars And Sense The bottom line is that every active landfill is going to have to spend some money. How much money is an entirely different question with as many possible answers as there are landfills. On the positive side, the economic impact of the new regulations on landfills can be as inexpensive as submitting a required design capacity report to the EPA and state agency, or as lucrative as the revenues realized from a gas-to-energy conversion system. The majority of landfills are too big to be exempt from further testing, but are probably too small to take on the major capital investment of an active gas collection system.
Landfills that are between tier I (below 150Mg/yr) and tier II (greater than 150 Mg/yr) should resubmit their report using site-specific tier II default parameters, Heitz recommends. Tier I testing uses the conservative EPA default parameter of 4,000 parts per million, while tier II uses a much lower default parameter of 1,170 ppm - a 30 percent reduction.
According to Tom Kerr, EPA Landfill Methane Outreach Program manager, the defaults used for the new regulations are conservative for the purpose of identifying larger methane-generating landfills and letting the smaller landfills test out through submission of tier II site-specific analysis.
"A lot of people don't realize how inexpensive a site-specific analysis is. When you consider spending $15,000 to conduct a test, compared to spending potentially millions of dollars in capital [on gas collection systems], it is worth the effort," Heitz says.
According to both Kerr and Heitz, the trend has been for larger landfills to resubmit site-specific tier II analysis back to EPA. Not many landfills are making the leap to methane collection systems voluntarily.
Heitz estimates the cost of installing a new gas collection system can range from $50,000 for utility flares to more than a $1 million for an active collection system. These costs do not include design fees, monitoring or repairs which can add thousands of more dollars to the price tag of complying with the new regulations.
A New Frontier The proposition of investing a million dollars into a new, active methane collection system can be ominous for any landfill operation. However, Kerr has observed that the new regulations have been a catalyst for many landfills.
"A lot of municipalities are seeing this as an asset, especially with the [potential] electricity deregulation," he says. "We're seeing folks who were skeptical of the new regulations at first now starting to see the regulations in a new light. It has given them a jumpstart to explore methane gas collection projects. They're working with other parties like local utilities, and we're starting to see these partnerships coalesce."
The Dane County Landfill in Madison, Wis., is an example of a municipality that didn't wait for the regulations to hit before constructing an active gas collection system.
According to Jerry Mandli, the county's solid waste director, the county chose to install an active gas collection system long before the new methane gas regulations were enforced. "By the time we had to file the initial NSPS requirements, we already had an active gas collection system in place," he says.
Dane County's new gas collection system is scheduled to go on line in October. Using two electrical generating sets, the landfill is turning methane into electricity and selling it back to the local utility.
The seven-million-cubic-yard facility is projected to generate $400,000 in electricity sales to Madison Gas and Electric per annum, and a buy-back rate of 2.4 cents per kilowatt has been set with the local utility.
Incidentally, this is not the first gas-to-electric conversion partnership Dane County has struck with Madison Gas and Electric. The county also has an electric-conversion system in place at its closed Verona landfill, which sells its electricity back to the utility for 2.6 cents per kilowatt.
The timing worked out well for Dane County. The regulations hit during the design phase of new gas collection system. No design modifications were needed to comply with the new regulation, although more time was required to comply with the air regulations. "We had to sort out the differences between the state and federal regulations," Mandli says.
A prime example of an active gas system coming to fruition as a direct result of the new methane regulations can be found at the J.C. Elliot Landfill in Corpus Christi, Texas. This municipally owned and operated landfill is in the process of constructing a gas-to-electric conversion system. A private contractor will perform the core drilling, extract the gas, convert it to electricity and sell it back to the local utility, Central and South West Corp., or to the city of Corpus Christi.
Plans for the project were initiated two years ago and were entirely motivated by the new methane regulations, according to West, who predicts the new system will be operational by the end of 1998.
The 400,000-tons-per-year, 21-acre landfill is expected to have a six-to-eight megawatt capacity. "The biggest obstacle has been the unwillingness of the local utility to purchase the electricity at anything other than the avoided cost," West says referring to Central and South West.
Central and South West, like most utilities in Texas, is an investment-based utility, and under state regulations must buy electricity generated by any source, he explains. However, it is only obligated to buy electricity at the avoided cost which, in the case of Corpus Christi, translates to two cents per kilowatt.
According to West, the landfill is in the midst of negotiations with the utility. "They [the utility] have a proposal out," he says. "We'd like to make it a win-win situation for all members."
Larry Jones, spokesperson for Central and South West Corp., Dallas, says his company has received 14 proposals in response to its request for proposals for up to 75 megawatts of electricity from renewable energy generators. RTC, Chicago, the independent contractor constructing the J.C. Elliot Landfill methane collection system, is one of the respondents.
All proposals are under consideration, and a decision is expected in December 1997 following final approval by the Public Utility Commission of Texas.
The avoided cost index set by the state is based on the actual cost for a utility to generate electricity, Jones explains. Texas requires utilities to buy back all electricity generated by alternative sources, including landfills. He notes the avoided cost rate for electricity has decreased since the section of the Industrial Fuel Use Act prohibiting the building of any new natural fuel electric generator plant was repealed five years ago (natural gas being the cheapest fuel, electricity now is cheaper to generate).
"It's understandable that a utility will not want to pay any more than it has to for electricity, because that means its customers are going to have to pay higher prices," Jones says, adding that the avoided cost is the benchmark for purchasing off-system electricity.
If negotiations are not successful with Central and South West, arrangements have been made for the city of Corpus Christi to buy back the electricity from itself. The project will succeed with or without the support of the utility, West says.
With the implementation of the new methane regulations across the country, an increasing amount of active collections systems will be constructed.
Currently, there are 250 new methane gas collection projects in the planning stages, compared with the 150 existing landfill gas collection systems in place before the new regulations, notes Kerr. Given this, however, the total economic ramifications of the new regulations have yet to be realized fully.