Tag Archives: greenhouse gas

Keeping the Lines of Communication Open Between Industry and the Federal EPA

December 20, 2017

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:

  • Outreach in early stages of the GHGRP development through recent decisions to utilize GHG emissions data from the GHGRP in the EPA’s current draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015 (GHG Inventory).
  • The initial implicit assumptions made by both the EPA and Stakeholders, using the reporting of “back-up devices” and the calculation of the fraction of time a destruction device was operating as an example of the assumptions made and an illustration of how those assumptions were implemented implicitly in the GHGRP.
  • How stakeholders have reached out to the EPA to address incorrect or misleading assumptions.
  • A summary of how stakeholders work to provide the EPA with additional data necessary to justify changes to the regulation, including revisiting oxidation factors that were rejected in the initial GHGRP and reducing methane measurement frequency at landfills.
  • How changes have improved landfill reporting under the GHGRP to make it more representative of actual emissions and more reflective of the sites that are reporting.
  • The unintended consequences of stakeholder outreach and revisions to the GHGRP for landfills.

 

Click here to read the paper.

 

Posted by Diane Samuels at 6:03 am
Tag Archives: greenhouse gas

NWRA and SWANA Provide Comments on the EPA’s Proposed Revisions to the Prevention of Significant Deterioration (PSD)

January 9, 2017

On behalf of the solid waste industry, the NWRA and SWANA  both not-for-profit associations provided comments on the EPA’s proposed Revisions to the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Permitting Regulations and Establishment of a Significant Emissions Rate (SER) for GHG Emissions Under the PSD Program (81 FR 68110), which we’ll call the PSD Revisions. The comments were submitted on December 16, 2016.

 

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:

  • Methane control devices that convert methane to CO2 and destroy NMOCs per the Landfill NSPS/EG Rules;
  • Engines and turbines that use landfill gas as fuel to produce renewable electricity;
  • Treatment of landfill gas to pipeline quality for use as renewable transportation or facility fuel; and
  • Methane that moves through landfill cover where bacteria converts it to CO2.

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.

 

 

 

 

Posted by Diane Samuels at 3:00 am
Tag Archives: greenhouse gas

Greenhouse Gas Fluxes and Carbon Storage Dynamics in Playa Wetlands: Restoration Potential to Mitigate Climate Change

March 31, 2016

Daniel_Dale_SCS_Engineers
Dale Daniel, SCS Engineers

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.

Read the article

Posted by Diane Samuels at 12:42 pm
Tag Archives: greenhouse gas

Greenhouse Gas Fluxes and Carbon Storage Dynamics in Playa Wetlands: Restoration Potential to Mitigate Climate Change

March 22, 2016

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.

Posted by Diane Samuels at 6:00 am
Tag Archives: greenhouse gas

The NWRA and SWANA React to EPA Region 2 Common Control Issue

January 29, 2016

The National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) returned comments and recommendations on the Environmental Protection Agency’s (EPA) draft Part 71 Operating Permit for Ocean County Landfill and MRPC Holdings LFGTE Operations, Permit Number: P71-0CMH-001 (Draft Permit) to EPA  Region 2 Permitting Section, Air Programs Branch. The letter was sent on January 28, 2016, to Mr. Steven C. Riva of the EPA.

NWRA and SWANA expressed concerned that the EPA’s issuance of the Draft Permit, and the circumstances under which it has been prepared, represent a significant departure from practical permitting policies and will constitute a disincentive to expand existing and develop future landfill gas-to-energy (LFGTE) projects around the country.

The jointly submitted comments from both not-for-profit Associations on the Draft Permit were intended to convey their members’ strong interest in these projects, which represent an economic investment in alternative renewable energy sources and the reduction in greenhouse gas (GHG) emissions. Both Groups have expressed concern that the EPA’s actions should not undermine those investments and the benefits derived from these LFGTE projects.

The main points of the letter cover the Associations’ disagreement with the EPA’s approach to common control. NWRA and SWANA support the position that the OCL and MRPC are two separate sources that are not under common control, and they oppose the position proposed by EPA Region 2 in the Draft Permit. Both Groups are urging EPA to re-evaluate this decision and utilize an environmentally beneficial approach when making common control determinations for landfills and third-party LFGTE plants both now and in the future. Other portions of the letter address the uncertainty that EPA’s position would create for affected facilities and how it could re-open already settled compliance expectations.

Members of NWRA and SWANA have access to the letter and may continue directing comments and questions through either Association.

Questions directed to SCS Engineers should be addressed to Pat Sullivan, Senior Vice President and the SCS National Expert on the Clean Air Act.

Learn more about SCS Clean Air Act Services, or Greenhouse Gas Services, or
Landfill Gas to Energy Services

Posted by Diane Samuels at 5:18 pm
Tag Archives: greenhouse gas

What do Climate Change, AB 32, and Ray Huff have in common?

October 22, 2015

GHG_AB32-scs-engineersThe Global Warming Solutions Act of 2006, or Assembly Bill (AB) 32, is a California State Law that fights climate change by establishing a comprehensive program to reduce greenhouse gas emissions GHG from all sources throughout the state.  AB 32 is the first state regulatory program in the country to take a comprehensive, long-term approach to addressing climate change. A major component of the program, the Landfill Methane Rule, requires landfill owner/operators to reduce methane emissions through proper operation of landfill gas LFG collection and control systems and collect and report  GHG emissions data in a timely manner. GHG emissions are defined in the AB 32 to include all of the following: carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, and perfluorocarbons.

SCS is a pioneer in our nation’s efforts to reduce GHG emissions in order to combat global warming. We proactively pursue the development of markets in which major sources of methane (e.g., oil and gas industry, landfills, dairies, etc.) can generate and sell GHG credits by voluntarily installing methane recovery systems and selling the methane as fuel.

Methane is 25 times more powerful than carbon dioxide in terms of its greenhouse effect. Capturing and destroying these emissions can have significant environmental benefits. Simply destroying methane via power generation or sequestration can diminish its GHG potential by 95 percent. Even greater benefits are available if the methane is used as renewable energy in order to offset natural gas or coal-fired power generation.

To learn more contact our Ray Huff, our SCS National Expert on Greenhouse Gas Monitoring, Control, and Emissions. 

Posted by Diane Samuels at 12:16 pm