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New 2010 Monitoring Requirements for Landfills

In an effort to better measure the amount of anthropogenic greenhouse gases (GHG) being released to the environment, and in response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law 110–161), the U.S. Environmental Protection Agency (EPA) passed the Final Mandatory Reporting of Greenhouse Gases Rule (FR 10-30-09, 40 CFR 98). The rule requires reporting of GHG emissions from large sources and suppliers in the United States, and is intended to collect accurate and timely emissions data to inform future policy decisions.

In general, the rule requires facilities that emit 25,000 tons of CO2 equivalents (CO2e) to report their emissions. The rule is expected to cover nearly 10,000 facilities, including 3,000 stationary combustion sources, 2,551 landfills, and the remaining facilities mostly consisting of natural gas suppliers, electric generators, pulp and paper mills, vehicle manufacturers, petroleum products suppliers, petroleum refineries, and iron and steel mills.

The principal greenhouse gases being monitored include carbon dioxide, methane, nitrous oxide, and fluorinated gases, including hydrofluorocarbon and perfluorocarbon. Landfills are the number two producer of methane in the United States behind enteric production. Methane is 21 times more destructive to the environment than carbon dioxide. Thus, one ton of methane is equivalent to 21 tons of carbon dioxide.

The first step a landfill owner must take is to understand whether or not the rule is applicable to their landfill facility. The applicability of the rule to landfills is defined by the facility’s production of methane. The production of methane in a landfill is dependent upon a number of key variables including, but not limited to, the volume of waste in place, the age of the waste, the waste composition, and moisture of the waste. Methane production is modeled using an EPAderived mathematical model. According to the Greenhouse Gas Reporting Rule and the EPA model, facilities that closed prior to Jan. 1, 1980, and also have less than 380,000 tons of waste in place are likely not subject to the rule. Also, based on the model, active or closed landfills that currently generate 270 scfm of landfill gas (at 50 percent methane) or more will be subject to the rule.

Once applicability of the rule is determined, landfills must develop a monitoring plan and collect data routinely throughout the year. Data to be collected includes waste disposal amounts (scale records), gas flow (continuous), gas monitoring at least weekly (temperature, pressure, moisture, methane content), and other operational parameters. This data must be reported annually to the EPA.

Terracon’s solid waste practitioners are assisting our clients with compliance with this new rule in a number of ways.

  • Rule applicability determination
  • Monitoring plan development
  • Weekly field monitoring
  • Automated data collection equipment retrofitting
  • Annual reporting

More information related to the GHG Rule can be found online at html.