Landfill-Gas-to-Energy Projects Sergio Guerra Kansas Department of - - PowerPoint PPT Presentation

Landfill-Gas-to-Energy Projects

Sergio Guerra

Kansas Department of Health and Environment

Bureau of Air

 1.0-Background  2.0-Landfill emissions  3.0-Subpart WWW  4.0-Landfill gas beneficial projects  5.0-Incentives for LFG utilization projects  6.0-Permitting challenges

• 1. Background

Types of Landfills

 Class I hazardous waste landfills  Municipal solid waste (MSW) landfills  Construction & demolition (C&D) landfills  Agricultural waste, mining waste, high-

volume industrial waste landfills

Developing Federal Rules

 Solid Waste Disposal Act of 1965  Resource Conservation and Recovery Act

• f 1976 (RCRA)

 Subtitle C for Hazardous Waste (HW) Landfills  Subtitle D for Municipal Solid Waste (MSW)

Landfills

RCRA Subtitle D

 40 CFR 257 Open Dump Inventory of

1978

 Required an inventory of open dumps vs.

landfills

 Open dumps had to upgrade or close within 5

years

 Sanitary landfills could remain open

 40 CFR 258 Sanitary Landfill Rules of 1991

 Upgraded landfills well beyond the old

definition

Subtitle D Provisions

 Location Restrictions  Operating Criteria  Design Criteria  Groundwater Monitoring  Landfill Closure  Post-Closure Care  Financial Assurance

Clean Air Act Regulation

 Clean Air Act (CAA) Amendments of 1990 started air

regulation of landfills

 Spawned landfill regulation by

 New Source Performance Standards (NSPS) / Emission

Guidelines (EG)

 Title V  Maximum Achievable Control Technology (MACT)  New Source Review (NSR)  Prevention of Significant Deterioration (PSD)

 Biggest impact is from NSPS  NSPS requires gas collection at all large landfills – includes

most landfills today

• 2. Landfill Emissions

Landfill Gas (LFG)

 Landfill gas is generated by the

decomposition process in landfills

 Creates mostly methane and carbon dioxide  And trace volatiles  Methane is the principal component of

natural gas

 Can be flammable and explosive  Can be used as a fuel

Landfill Gas (LFG)

 Methane a greenhouse gas

 Methane absorbs terrestrial infrared radiation (heat)

that would otherwise escape to space (GHG characteristic)

 Methane as GHG is over 20x more potent

by weight than CO2

 Landfills were the second largest human-

made source of methane in the United States in 2006, accounting for 22.6% generated

Landfill Gas Hazards

 Methane can migrate from landfills and

burn or explode in confined space

 Has caused injury and death  Trace gases can create odor problems  Trace volatiles can create air pollution

Landfill Gas Benefits

 The methane in landfill gas can be captured and

used as a fuel

 Common LFGE applications are:

 Direct-use (boiler, heating, direct thermal)  Combined Heat & Power (engine, turbine,

microturbine)

 Electric (engine, turbine, microturbine)

 There are 400 LFGE projects in the U.S.  And another 200 elsewhere in the world today

• 3. NSPS Subpart WWW

 NSPS (New Source Performance

Standards) for MSW Landfills, 40 CFR Part 66 Subparts Cc and WWW, promulgated March 12, 1996 requires control of landfill gas when the landfill capacity exceeds:

 2.5 million m3 AND  2.5 million megagrams AND  NMOC emissions exceed 50 megagrams/yr

Effect of the NSPS

• Air Emissions become a concern
• Increased scrutiny of landfill air emissions
• New Permit and Regulatory Requirements

 More Monitoring and Testing  More Records  More Reports

Importance of NSPS

Applicability: Primary trigger based upon the landfill meeting the Area Source Criteria in 40 CFR 63.1935(a)(3)

Importance of NSPS

Compliance: Landfills compliance is based upon the NSPS, EG or Approved Alternative as per the NSPS/EG (40 CFR 63.1955(a) or (c))

NSPS - Applicability

The NSPS applies to MSW landfills for which construction, modification, or reconstruction commences on or after May 30, 1991

Control Requirement

• Design capacities greater than or equal to

2.5 million Mg and 2.5 million m3

• NMOC Emissions Greater than 50 Mg/yr

NMOC Emissions

• 40 CFR 60.754(a)(1)(i)

n

MNMOC=  2 k Lo Mi ( e-kti) (CNMOC) (3.6 x10-9)

i= 1

• 40 CFR 60.754(a)(1)(ii)

MNMOC= 2 Lo R (e-kc - e-kt) (CNMOC) (3.6 x10-9)

1.00 10.00 100.00 1000.00

1 9 7 6 1 9 8 6 1 9 9 6 2 6 2 1 6 2 2 6 2 3 6 2 4 6

Year M g /Y r

NMOC Emission Rate

CAA AP-42

Tier 1; 40 CFR 60.754(a)(2)

• No Testing Required
• Default Equation Values are Used
• Calculation & Report Required Within

90 days of being affected 40 CFR 60.757(b)(1)(i)(B)

Tier 2; 40 CFR 60.754(a)(3)

• CNMOC Determination Required
• Calculation & Report Required Within

180 days after the first 50 Mg exceedance 40 CFR 60.757(c)(1)

Tier 3; 40 CFR 60.754(a)(4)

• k Determination Required
• Calculation uses the Tier 2 CNMOC
• Calculation & Report Required Within 1

year after the first 50 Mg exceedance 40 CFR 60.757(c)(2)

GCCS plan

Landfill Gas Collection and Control System Design Plan required within 1 year of the first report which the emission rate equals

• r exceeds 50 Mg per year.

40 CFR 60.752(b)(2)(i) and 60.757(c)

Collection System Requirements

 Maximum gas flow rate  Collect Gas from all areas in which

solid waste has been placed for:

 5 years or more if active; or  2 years or more if closed or at final

grade.

 Sufficient Extract Rate  Minimize off-site Migration

Control System : # 1

• Open flare; or
• A control system designed and
• perated to reduce NMOC by 98% by

weight; or

[40 CFR 60.752(b)(2)(iii)(A) & 40 CFR 60.752(b)(2)(iii)(B)]

Control System: # 2(a)

• A enclosed combustor which reduces

NMOC by 98 weight percent or reduce the outlet NMOC concentration

[40 CFR 60.752(b)(2)(iii)(B)]

Control System: # 2(b)

Reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen.

Control System: # 3

• Route the collected gas to a treatment

system that processes the collected gas for subsequent sale or use

[40 CFR 60.752(b)(2)(iii)(C)]

GCCS Startup

Installation of Landfill Gas Collection and Control System Completed within 30 months after reporting NMOC emissions

 50 Mg/yr

40 CFR 60.752(b)(2)(ii)

Reporting Requirements # 1

• Initial and annual design capacity report
• NMOC emission reports (Annual or 5 year

Reports)

• Notification of increases in design

capacity and NMOC emissions

Reporting Requirements # 2

• Submittal of design plans and

construction permit applications

• Compliance certifications
• System Removal Reports
• Annual Emission Report
• Excavation in Asbestos Areas

Recordkeeping # 1

• Control and Emission Exceedances
• Location of Asbestos
• Waste Acceptance Rate
• Asbestos Waste Shipment Records

Recordkeeping # 2

• Gas Collection and Control Equipment

Operating Parameters

• New Well Installation
• Monitoring Parameters

Landfill Air Regulations - MACT

 MSW Landfill MACT (Maximum Achievable

Control Technology), 40 CFR Part 63-Subpart AAAA applies to those NSPS regulated landfills requiring control (NMOC emissions 50 Mg/yr or more), and requires:

 Immediate control of landfill gas from

bioreactors

 Startup, Shutdown, & Malfunction (SSM) Plan  Semiannual Reporting  Continuous monitoring of control device

• perating parameters

Title V Requirement

 June 10, 1996 for MSW landfills that

commenced construction, modification, or reconstruction on or after May 30, 1991 but before March 12, 1996;

 Ninety days after the date of commenced

construction, modification, or reconstruction for MSW landfills that commence construction, modification, or reconstruction on or after March 12, 1996.

• 4. Landfill Gas Beneficial Projects

Landfill Gas and Green Power A Winning Combination

 Dual benefit  destroys methane and other

• rganic compounds in LFG

 Offsets use of nonrenewable resources (coal,

• il, gas) reducing emissions of SO2, NOX, PM,

CO2

 LFG is a recognized renewable energy resource

(Green-e, EPA Green Power Partnership, 33 states, Sierra Club, NRDC)

 LFG is generated 24/7 and projects have online

reliability over 90%

 LFG can act as a long-term price and volatility

hedge against fossil fuels

Common LFGE applications

 Direct-use (boiler, heating, direct

thermal)

 Combined Heat & Power (engine, turbine,

microturbine)

 Electric (engine, turbine, microturbine)

State of the National LFG Industry (April 2009)

 At least 485 operational projects in 44 states

supplying:

 12 billion kilowatt-hours of electricity and 85 billion

cubic feet of LFG to direct-use applications annually

 Estimated ‘09 Annual Environmental Benefits

 Carbon sequestered annually by ~ 19,500,000 acres

• f pine or fir forests, or

 CO2 emissions from ~ 199,000,000 barrels of oil

consumed, or

 Annual greenhouse gas emissions from ~ 15,700,000

passenger vehicles

 Estimated Annual Energy Benefit

 Powering more than 889,000 homes and

heating nearly 614,000 homes

Diversity of Project Types

Electricity Generation

Internal Combustion Engine (range from 100 kW to 3 MW) Gas Turbine (range from 800 kW to 10.5 MW) Microturbine (range from 30 kW to 250 kW)

File Last Updated: April 2009

• 5. Incentives for LFGE projects

LFG and State Renewable Portfolio Standards

 Renewable Portfolio Standard (RPS) –

requires utilities to supply a percentage of power from renewable resources

 28 states plus District of Columbia have an RPS

 Renewable Portfolio Goal (RPG) – same as

RPS except an objective not a requirement

 5 states have an RPG

 LFG is eligible as a renewable resource for

33 states and District of Columbia

LFG and RECs

 Renewable Energy Certificates (RECs)

 Equivalent to 1 MWh of renewable energy

generation

 From $5 to $50 per MWh (0.5 to 5 cents per kWh)

 Companies looking to reduce their

environmental footprint purchase RECs from utilities using LFG

 DuPont – 170 million kWh from biomass & LFG  Pitney Bowes – 10% of electricity from wind & LFG  Staples – 46 million kWh/year of RECs, 90% from

biomass & LFG

Public and Private Entities Moving to Reduce GHG Emissions

 Voluntary Markets

 Currently where most GHG activity occurs  Examples - Chicago Climate Exchange, Blue

Source

 Compliance Markets

 Rapidly evolving, will become the dominant

market

 Led by Massachusetts and California and

regional efforts

Emissions Trading of LFG

 Chicago Climate Exchange (CCX) is an example of a

voluntary GHG reduction and trading program

 Offers a credit of 18.25 metric tons CO2 per metric ton of methane

combusted

 Applicable for LFG collection and combustion systems placed into

service after 12/31/98

 Prices range from $1 to $6.50 per metric ton (market factors affect

pricing)

 Only landfills not required by federal law (e.g., NSPS) to combust

LFG are eligible

 Landfill methane emission offsets brochure at

www.chicagoclimateexchange.com

Federal Financial Incentives

 Section 45 Production Tax Credit (PTC)

• Electricity generation – 1.0 cent/kWh
• Placed in service by 12/31/13
• 10-year window for credits
• Under Economic Stimulus Bill: Short-term option to select a
• ne time 30% investment tax credit (Section 48) or convert

into a 30% cash grant

 Clean Renewable Energy Bonds (CREBs)

• National allocation of $2.4 billion
• In 2008, IRS granted issuance of 45 bonds for LFGE projects

 Renewable Energy Production Incentive (REPI)

• Local/state government or non-profit electric co-op facilities
• Online by 10/1/16
• Payment for first 10 years of operation

Many Untapped LFG Resources

 Currently ~ 520 candidate landfills with a total gas

generation potential of 200 billion cubic feet per year (~ 12,000 MMBtu/hr) OR electric potential of 1,180 MW (~ 9.5 million MWh/yr)

 If projects were developed at all these landfills,

estimated

 Annual Environmental Benefit =

Carbon sequestered annually by ~ 11.5 million acres of pine or fir forests OR annual greenhouse gas emissions from ~ 9.2 million passenger vehicles, AND

 Annual Energy Benefit =

Powering 698,000 homes OR heating 1.4 million homes per year

Many Untapped LFG Resources

(cont.)

 ~ 500 landfills have a gas collection

system but no energy project

 Potential of 263,000 MMBtu/day or 1,040 MW

 ~ 95 landfills have an energy project and

excess LFG available

 Potential of 60,000 MMBtu/day or 235 MW

 ~ 970 landfills do not have a gas

collection system

 Potential of 206,000 MMBtu/day or 815 MW

Untapped LFG-Carbon Credit Resources

 Currently ~ 470 landfills without an operational project

and indicated to not be currently required by federal regulation to collect & combust LFG

 More than 1.3 million short tons CH4/yr reduction potential (26

MMTCO2E/yr or 7 MMTCE/yr)

 Gas generation potential of ~ 115 billion cubic feet/yr (~ 6,700

MMBtu/hr) OR electric potential of ~ 640 MW (~ 5 million MWh/yr)

 If projects were developed at all these landfills,

estimated

 Annual Environmental Benefit from CH4 reduction =

Carbon sequestered annually by ~ 5.7 million acres of pine or

fir forests OR annual greenhouse gas emissions from ~ 4.6 million passenger vehicles,

AND

 Annual Energy Benefit =

Powering 377,000 homes OR heating nearly 838,000 homes per year

• 6. Permitting Challenges

Single vs. Separate Sources

Collocated sources are considered a single source when the following three criteria are met.

1.

Contiguous or adjacent property

2.

Same two-digit primary SIC code (or one facility is considered a support facility to the other)

–

4953: Refuse Systems

–

4911: Electric Services (other electric power generation)

3.

Common Control

[40 CFR Sections 70.2, 71.2, 63.2, 51.165(a)(1)(i) and (ii), and 51.166(b)((5) and (6))]

Common Control Issues

 Liability  Aggregate emissions  Financing  Insurance

Common Control

 Presumption: Company locating on

another’s land establishes a common control relationship.

 Rebuttal of presumption of common control

is the burden of the source.

 Decided on a case by case basis.

Determination of common control

[Letter to Peter Hamlin from U.S. EPA Region VII- 9/18/1995]

 Need to ask questions about interaction

between two companies.

Do the facilities share:

 common workforces, plant managers,

executive officers?

 equipment, other property, or pollution

control equipment?

 intermediates, products, byproducts?

Determination of common control

 What is the dependency of one facility on

the other?

 Does one operation support the operation

• f the other?

 What is the dependency of one facility on

the other?

 Who is ultimately responsible for

compliance with Subpart WWW?

Example 1

 Landfill has agreed to sell LFG to energy plant  Energy plant is built on leased land from landfill  Energy plant will control valve to route LFG to engines or

flare

 Whenever LFG is not used, it will be flared at the landfill  Parties do not have any financial interest in one another  Up to 70% of energy plant’s needs could be met by LFG  Engines at energy plant may run on different types of

liquid fuels, supplemented by landfill gas

 Engines cannot operate using only landfill gas

Example 1

 May 1, 2002 EPA determination from Judith Katz

at EPA Region III regarding:

 Maplewood Landfill and Industrial Power Generation

Corporation (INGENCO)

 Landfill and Energy plant are NOT under

common control

 There are no financial interest in one another  Do not share intermediates, products, byproducts etc.  Maplewood receives power through local power utility

(won’t receive power directly from INGENCO)

 No arrangements for Maplewood to accept

INGENCO’s municipal solid waste

 Finally, neither facility is dependent on the other. If

either of them shut down they can continue to

• perate at full capacity.

Example 2

 Landfill has agreed to sell LFG to energy plant  Energy plant is built on leased land from landfill  Energy plant will control valve to route LFG to engines or

flare

 Whenever LFG is not used, it will be flared at the landfill  At some point Landfill parent company “A” also owned

stock in energy plant.

 Stock on energy plant were sold back  Transfer of stocks still needed approval from Landfill company “A”

 Energy plant depends on landfill as its only source of fuel  Energy plant and landfill cannot sell or transfer gas

without approval from landfill company “A”

Example 2

 May 11, 2009 letter from Ronald Brosellino at EPA

Region II regarding:

 Common control determination for Ocean County Landfill (OCL)

and Manchester Renewable Power Corp. (MRPC)

 Landfill and Energy plant are under common control for

PSD, NSR, and title V programs of Clean Air Act

 Landfill’s parent company still retained control over stocks from

Energy plant.

 Dependence of MRPC on OCL for its source of fuel  Landfill’s parent company had control over sale or transfer of

landfill gas for both companies

 Companies shared tax credits  Existing title V permits for OCL and MRPC must be reopened and

reissued to both companies as a single source

Example 3

 Landfill has agreed to sell LFG to energy plant  Energy plant is built on leased land from landfill  Energy plant will control valve to route LFG to engines or

flare

 Whenever LFG is not used, it will be flared at the landfill  Parties do not have any financial interest in one another  Engines at energy plant may run on different type of fuel

(i.e. propane) but clearly not the intention

 Engines can operate using only landfill gas

Oak Grove Landfill and Oak Grove Power Producers

 KDHE determined both companies were

under common control

 A construction approval was issued to

energy plant

 Energy plant is also required to apply for

Class I permit

 Air emissions are to be aggregated for air

permitting purposes

LFG beneficial projects in Kansas

 Treatment facility

 SouthTex at Deffenbaugh landfill in Johnson Co., KS

(in operation)

 LFGE facility

 Rolling Meadows Landfill, Shawnee Co., KS

(in construction)

 Oak Grove Power Producers, Crawford Co., KS

(permitted)

 Boiler combusting LFG

 Abengoa Bioenergy from Brooks Landfill at Sedgwick

Co., KS

Guidance and I nfo

• USEPA’s Websites

NSPS -

http://www.epa.gov/ttn/atw/landfill/landflpg.html

MACT (AAAA) -

http://www.epa.gov/ttn/atw/landfill/lndfillpg.html

USEPA Applicability Determination I ndex (ADI ) http://cfpub.epa.gov/adi/index.cfm Landfill Methane Outreach Program (LMOP)

http://www.epa.gov/landfill/index.htm

 Sergio Guerra  Bureau of Air, KDHE  sguerra@kdheks.gov  (785) 296-0365