The coronavirus, COVID-19 outbreak has caused widespread disruptions as communities implement protective public health measures. Due to this situation, facilities may encounter difficulties that prevent them from submitting their Annual GHG reports for reporting year 2019 by the March 31, 2020 deadline.
EPA’s electronic Greenhouse Gas Reporting Tool supports facility and supplier reporting for the EPA Greenhouse Gas Reporting Program. The e-GGRT system will remain open past this deadline for all first-time submissions and resubmissions. Log-in here. The same URL has new user registration and help with retrieving lost passwords.
New to e-GGRT? Get help here.
The GHGRP requires reporting of greenhouse gas (GHG) data and other relevant information from large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites in the United States. Approximately 8,000 facilities are required to report their emissions annually, and the reported data are available to the public in October of each year.
Greenhouse Gas Services – SCS clients may direct questions to their project manager or contact us at service@scsengineers.com
California leads the way in the United States with a GHG MRP and C&T program that continues to grow and link with other jurisdictions. The California Air Resources Board (CARB) Market Readiness Proposal initially started with basic facility reporting and has grown and adopted to include multiple non-facility specific sectors of the economy, as dictated by the growing initiatives and programs that CARB joins or creates. However, as the program applicability may change, the basics tenants of MRP stay the same with reporting and verification at the center of the program.
By having CARB’s C&T Program as a separate program, entities have to navigate if they have a compliance obligation and how they will meet that obligation in addition to complying with reporting requirements. Entities can reduce their emissions by switching to biomass-derived fuels or meeting their compliance obligation by using CARB-provided allowances or purchasing allowances and/or compliance offset credits.
As CARB’s programs grow, it will likely trigger similar growth in the western North American GHG programs and regional agreements. As discussed, Québec’s C&T system, which is linked with CARB’s program, has been growing and is being used to meet the Canadian federal GHG rules that are being put in place. Ontario’s program was annulled but shows that the discussion on how best to reduce GHG emission is a topic that continues to thrive, and we may see new programs developing even though some may hit some setbacks. The PCC shows that even if a Market Readiness Proposal and C&T Program is not the particular method chosen by a region to reduce emissions, many regions still see reducing GHG emissions as the future to create jobs, develop the economy, develop new infrastructure and maintain growth while protecting the environment.
About the Authors:
Cassandra Drotman Farrant is experienced in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. She has participated in GHG verification projects throughout the U.S.
Raymond H. Huff is SCS Engineers’ National Expert on Greenhouse Gas. He specializes in landfill regulatory compliance; air quality/compliance issues, including GHG emissions quantification; and site assessment, remediation, and post-closure care.
Haley DeLong is experienced in greenhouse gas (GHG) emissions, sustainable energy, and climate dynamics. She specializes in air quality consulting and has been involved in numerous projects related to air permitting and compliance with solid waste regulations, including preparing Title V and Non-Title V permit-to-construct/operate permit applications.
Dr. Iyer is a Staff Professional at SCS focusing on environmental research and engineering in water, wastewater, solid waste, and landfill design. Gomathy is another of our remarkably talented young professionals utilizing her expertise in leachate management and landfill design to support her clients.
We hope you will attend Gomathy’s presentation “Suitability of Un-Composted Grass Clippings and Biosolids as Biocovers for Biological Methane Removal from Landfills,” on Tuesday, February 25 at 8:30 am (Track B: Landfill Covers), at the 2020 Global Waste Management Symposium. Her presentation is based on a technical paper of the same name and co-authored with Melanie Sattler of the University of Texas at Arlington, and Darrin Dillah of SCS Engineers.
Landfill biocovers are widely used to oxidize methane emissions, a known greenhouse gas. The biocovers in use today are typically either fully or partially made of composts. However, the production of compost, although theoretically an aerobic process, also produces potentially substantial quantities of methane, from 3.2 to 362 kg carbon dioxide (CO2)-equivalents per ton of wet waste composted, depending on various factors, for example, the type of waste, and open or enclosed composting technology. This research explored the suitability of using uncomposted grass clippings as a biocover for methane removal from landfills, with the aim of reducing net greenhouse gas emissions.
Physical and chemical characteristics of grass clippings along with other components of yard waste were studied and compared. The use of biosolids and fly ash as potential bulking materials were considered since the physical and chemical characteristics of biosolids and fly ash complemented the grass clippings and biosolids were expected to provide a good inoculum of microbes for the biocover. Batch tests were performed on the grass clippings and combinations of grass, biosolids and fly ash mixtures for aerobic methane removal. Grass clippings were found to have a maximum methane removal rate of 2,121.7 nmol/kg/s, and a combination of grass and biosolids showed a maximum methane removal rate of 4,410.8 nmol/kg/s. Analyzing different proportions of grass, biosolids and fly ash mixtures, it was found that a 70% grass, 21% biosolids and 9% fly ash mixture exhibited the highest methane oxidation of 5,862.5 nmol/kg/s.
Column tests were performed on the grass clippings and on a combination of 70% grass, 21% biosolids and 9% fly ash by introducing a continuous flow of 50% methane and 50% carbon dioxide at the bottom of the column reactor containing 2 feet of biocover material. The column reactors with grass clippings showed a methane removal of 90-100% within the first 10 days, and the reactors with the combination of grass, biosolids and fly ash showed a methane removal of 90-100% within first 3 days. Biocover performance indexes were calculated based on the performance of each biocover. The biocover performance index for grass was found to be 20.8 µg/g/hr and that for the combination of 70% grass, 21% biosolids and 9% fly ash was found to be 43.3 µg/g/hr.
Representative samples were taken from the column reactors to analyze for the presence of methanotrophs involved in the methane removal process. A PCR (Polymerase Chain Reaction) analysis was performed on these samples with A189 (forward) and A682 (reverse) primers. The evidence of pMMO PCR amplification products was seen in all column reactor samples, indicating the presence of the pMMO gene, which is found in methanotrophs and hence confirmed the presence of methanotrophs. A BLAST (Basic Local Alignment Search Tool) was performed on the sequence obtained from the PCR analysis confirmed methalocystis and type 2 methanotrophs. Figure 1 shows the gel picture of the PCR analysis of the column reactor samples. #1
LEAF testing was conducted to analyze the leachability of fly ash in the biocover. It was seen that silver, arsenic, cadmium, chromium and thallium exceeded the permissible level in drinking water. Hence, it was concluded that the grass clippings by itself or a combination of grass and biosolids can be used as a biocover for biological methane removal.
Global Waste Management Symposium 2020
February 23 @ 8:00 am – February 26 @ 5:00 pm
2020 GWMS Information
This proposed MSW Landfills Federal Plan includes the same elements as required for a state plan: identification of legal authority and mechanisms for implementation; inventory of designated facilities; emissions inventory; emission limits; compliance schedules; a process for the EPA or state review of design plans for site-specific gas collection and control systems (GCCS); testing, monitoring, reporting and record-keeping requirements; public hearing requirements; and progress reporting requirements. Additionally, this action summarizes implementation and delegation of authority of the MSW Landfills Federal Plan.
This proposed action addresses existing MSW landfills and associated solid waste management programs. For the purpose of this regulation, existing MSW landfills are those that accepted waste after November 8, 1987, and commenced construction on or before July 17, 2014.
Tables 1 and 2 in the publication list the associated regulated industrial source categories that are the subject of this action and the status of state plans. The EPA tables are not intended to be exhaustive but do provide a guide for readers regarding the entities that this proposed action is likely to affect. The proposed standards, once promulgated, will be directly applicable to the designated facilities.
The document contains the full text and how/when to comment or appear at the public hearing. Feel free to share this document or page with others using the icons at left.
By keeping open lines of communication between industry stakeholders and the U.S. EPA at a federal level, both parties have been able to improve the quality of GHG emissions data reported under the GHGRP while reducing the monitoring burden.
Read this SCS Engineer’s abstract that discusses the cooperation between the U.S. Environmental Protection Agency (EPA) and solid waste industry stakeholders in developing, revising, and implementing the landfill reporting requirements as part of the federal GHG Reporting Program (GHGRP) (40 CFR Part 98). The paper covers:
Drones might be the best solution for topography surveying and other supporting activities in landfills operations and design. With quick turn around this technology is cost effective for generating topography maps and volume determination.
Drone versatility, accuracy, and easily use are key factors to make an efficient investment decision as the operators of the Nortes III Landfill determined when implementing their program two years ago. For example, at Nortes a total station takes 2-days/Ha to carry out a survey and 3D modeling, whereas a drone takes 2 hours for the similar end products.
Learn more about the advanced uses of proven technology to reduce operating costs, improve design, increase safety and efficiency. Technology companies come and go, but SCS Engineers remains at the forefront by applying new processes and technologies to improve and adapt business operations to environmental, social, economic, and regulatory change.
Continuous improvement, our in-the-field experience, and our deep involvement in the industries we serve help us deliver smart and simple solutions that work.
EPA is proposing a GHG SER of 75,000 tons per year (tpy) Carbon Dioxide equivalent (CO2e) and requesting comment on it as well as two lower levels, specifically 30,000 tpy and 45,000 tpy CO2e, respectively.
The Associations do not believe there is sufficient information to support lowering the GHG SER below the proposed 75,000 tpy CO2e level and provided a table utilizing equivalent criteria pollutants from combustion sources (i.e., NOx, CO) yields CO2 emissions as high as 780,000 tpy CO2.
EPA already concluded in USEPA, Proposed PSD Revisions Rule, 81 FR 68137 that the burdens of regulation at a GHG SER level between 30,000 and 75,000 tpy CO2e would yield a gain of trivial or no value from both a programmatic and individual project-level perspective. Therefore, NWRA and SWANA strongly recommend EPA retain proposed GHG SER of 75,000 CO2e (or higher), and resist pressure to lower the GHG SER.
On the Topic of Biogenic GHG Emissions, the EPA’s final rule requires clarification to remain consistent with previous documentation and research to prevent significant permitting delays and increased costs that will not result in meaningful emission reductions.
The Associations encourage the EPA to ensure that waste-derived biogenic CO2 (e.g., from municipal solid waste (MSW) landfills) is treated as carbon neutral under the final PSD Permitting Revisions Rule to be consistent with prior Agency determinations specified in this memorandum and documents as follows:S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014.
S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014. The documents highlight waste-derived, biogenic CO2 as a type of “carbon neutral” feedstock based on the conclusions supported by a variety of technical studies and conclusions of the Agency’s latest draft Framework for Assessing Biogenic Carbon Dioxide for Stationary Sources, which was released with the memo. The Agency memo stated that “the Agency expects to recognize the biogenic CO2 emissions and climate policy benefits of such feedstocks in [the] implementation of the CPP.”
US EPA, Emission Guidelines for EGUs, 80 FR 64855. Both the revised Framework, and the EPA’s Scientific Advisory Board (SAB) peer review of the 2011 Draft Framework, found “that the use of biomass feedstocks derived from the decomposition of biogenic waste in landfills, compost facilities, or anaerobic digesters did not constitute a net contribution of biogenic CO2 emissions to the atmosphere.”
S. EPA, Appendix N. of Revised Framework for Assessing biogenic Carbon Dioxide for Stationary Sources, November 2014, pg. N-25. In Appendix N. of the Framework, entitled Emissions from Waste-Derived Biogenic Feedstocks, EPA calculated negative Biogenic Accounting Factors (BAF) for various examples of treatment of landfill gas via collection and combustion. EPA explains, “Negative BAF values indicate that combustion of collected landfill gas feedstock by a stationary source results in a net CO2e emissions reduction relative to releasing collected gas without treatment.”
US EPA, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units; Final Rule [Emission Guidelines for EGUs], 80 FR 64885. “[T]he use of some biomass-derived fuels can play a role in controlling increases of [in] CO2 levels in the atmosph The use of some kinds of biomass has the potential to offer a wide range of environmental benefits, including carbon benefits.”
US EPA, Emission Guidelines for EGUs, 80 FR 94855. Types of waste-derived biogenic feedstocks may include: landfill gas generated through decomposition of MSW [municipal solid waste] in a landfill; biogas generated from the decomposition of livestock waste, biogenic MSW, and/or other food waste in an anaerobic digester; biogas generated through the treatment of waste water, due to the anaerobic decomposition of biological materials; livestock waste; and the biogenic fraction of MSW at waste-to-energy facilities.
NWRA and SWANA believe the final PSD Revisions document should follow the approach to waste-derived feedstocks enshrined in the Final Clean Power Plan, and as recommended by the SAB, and ensure that waste-derived biogenic CO2 is treated as carbon neutral. Based on EPA’s own lifecycle assessments for the Renewable Fuels Standard program, its U.S. GHG Inventory, and confirmed by the SAB, EPA has sufficient analysis to support exclusion of selected categories of biogenic emissions from PSD permitting, including those from managing landfill gas and organic components of MSW.
The EPA does not seem to consider the regulatory treatment of biogenic CO2 from stationary sources to be a key issue in the context of the PSD revisions rule, based on a comment found in a Summary of Interagency Working Comments on Draft Language. Instead, the EPA continues to believe this rulemaking to establish a GHG SER under the PSD program is not the appropriate venue to address the broader concern of the regulatory treatment of biogenic CO2 from stationary sources.
The Associations strongly disagree and are concerned that because EPA remains silent on this important issue, some permitting authorities might improperly require landfills to incorporate biogenic CO2 emissions in the PSD permitting process. Historically, few landfills triggered PSD because non-methane organics emissions rarely reached the threshold. However, if biogenic CO2 emissions become subject to PSD, many landfill projects, which are “anyway sources” due to renewable energy projects, would also be forced to do BACT analysis for GHG. Biogenic CO2 is emitted from:
From the perspective of developing new renewable transportation fuel or energy projects, subjecting biogenic emissions from landfills to PSD could be an enormous barrier. The Associations would like the EPA to clarify in its final rule that the emissions of biogenic CO2 from treating or controlling landfill gas does not increase the CO2 levels in the atmosphere, but instead, has positive emission reduction and climate benefits. Failing to clarify this important point could subject landfills to significant permitting delays and increased costs that will result in no meaningful emission reductions.
Questions? Contact SWANA, NWRA, Patrick Sullivan, or your local SCS office.
Our latest SCS Technical Bulletin summarizes the EPA federal mandatory greenhouse gas (GHG) reporting program (GHGRP) into two pages of the most vital information. The new reporting requirements for Subparts HH and A discussed in our bulletin are effective January 1, 2017.
Remaining updates will be phased in from 2017 to 2019. These updates include, but are not limited to, revisions to the reporting regulation for all reporters including Subpart A Administrative Requirements, Subpart C Stationary Combustion Sources, and Subpart HH Municipal Solid Waste Landfills the three most common reporting sectors for MSW landfills. SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed.
Use our resources for guidance or to answer questions.
Share, read, or print the Technical Bulletin
Greenhouse Gas Service Information
Dr. Dale W. Daniel, an Associate Professional with SCS’s Oklahoma City office, recently published a summary article of his dissertation research through the U.S. Department of Agriculture’s Conservation Effects Assessment Project. The primary goal of the research was to provide under-standing of the potential climate mitigation services provided through wetland conservation and restoration in the High Plains region of the United States. Focus was placed on greenhouse gas (GHG) emissions from wetlands and adjacent upland landscapes as well as identifying some of the drivers of GHG flux that are influenced by various land management practices. The project also sought to understand how sediment removal from wetland basins influenced Carbon and Nitrogen content as well as Carbon sequestration services.
In 2007, the Society for Ecological Restoration International (SER) stated that global climate change is a real and immediate threat that requires action, and ecological restoration is one of the many tools that can help mitigate that change (SER 2007). However, recent debate within the conservation science community has arisen concerning whether restoring ecosystems for C offset projects may shift focus away from other important benefits to society (Emmett-Mattox et al. 2010). Indeed, not all ecosystem restorations make viable ecological offset projects for industries seeking to reduce their C emissions, and those that do, may not always occur in areas where restoration funding is needed the most. This study demonstrated that management practices focused on restoring natural landscape functions, including native species plantings and basin sediment removal, can increase climate mitigation services provided by wetland and upland ecosystems within a region heavily impacted by land use change.
Dr. Dale W. Daniel, a professional with SCS Engineers recently published a summary article of his dissertation research through the U.S. Department of Agriculture’s Conservation Effects Assessment Project. The primary goal of the research was to provide understanding of the potential climate mitigation services provided through wetland conservation and restoration in the High Plains region, U.S. Focus was placed on greenhouse gas (GHG) emissions from wetland and adjacent upland landscapes as well as identifying some of the drivers of GHG flux that are influenced by various land man¬agement practices. They also sought to understand how sediment removal from wetland basins influenced C and N content as well as C sequestration services.
Read the article and findings.
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