epa emissions rule of thumb

some baseline statistics needed

6 messages

MarniJ Zollinger <[email protected]>

MarniJ Zollinger <[email protected]> Wed, Jan 23, 2008 at 10:48

AM To: [email protected] Cc: Michael McCall <[email protected]>, Mark Alexander <[email protected]>

Greetings again Ms. Swarupa, We spoke on the phone a few days ago. I was interested in obtaining a general understanding of how federal regulations were enforced for landfill emissions when de minimus levels of emissions appeared to be regularly exceeded by landfill emissions at all times, if properly calculated over the lifetime greatest decay (25 years?). You were able to help me by offering basic calculations that are used for carbon credit emissions. I have some general questions: 1. Can you please provide the rule of thumb emissions production in tons that are used per 1 ton, per 100 tons, and per 500 tons of class I (household) MSW? 2. Is it possible that you could obtain through your consultant contacts, a baseline emissions profile of a landfill that accepts 500 tpd of Class I MSW, measuring the emissions in tons per year? 3. I have noticed that there are many models (with differing years of study-- some go out 20 years, others go out 40 years) of projecting the MSW decay, can you provide me with the data for model of decay accepted by the EPA for the purpose of calculating credits? Many thanks, Marni Zollinger, CEO -- Cob Creations, LLC (877) 300-0187 x 701 (801) 404-2759 direct cell (309) 422-7653 fax [email protected]

[email protected] <[email protected]> Fri, Jan 25, 2008 at 1:39 PM To: MarniJ Zollinger <[email protected]> Cc: Mark Alexander <[email protected]>, [email protected], Michael McCall <[email protected]>

Good afternoon, Marni. I have received your request and already discussed an approach to answer your questions with our contracting specialists. We will send you some preliminary answers by early next week. Regards, Swarupa Ganguli, Program Manager EPA Landfill Methane Outreach Program (LMOP) Mail: USEPA (6207J), 1200 Pennsylvania Avenue, NW, Washington, DC 20460 Office: USEPA (6207J), 1310 L Street, NW, Washington, DC 20005 202-343-9732 (Phone), 202-343-2202 (Fax)

of 6Gmail - some baseline statistics needed

2/3/2008http://mail.google.com/mail/?ui=1&ik=6df1623936&view=pt&th=117d1a628c8e1a62&sear...

"MarniJ Zollinger" <marnizollinger@ To cobcreations.com Swarupa Ganguli/DC/USEPA/US@EPA > cc Sent by: "Michael McCall" marnizollinger2@ <[email protected]>, "Mark gmail.com Alexander" <[email protected]> Subject some baseline statistics needed 01/23/2008 01:48 PM

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MarniJ Zollinger <[email protected]> Fri, Jan 25, 2008 at 4:02 PM To: "[email protected]" <[email protected]> Cc: Mark Alexander <[email protected]>, Michael McCall <[email protected]>

I thank you and your team. We look forward to that information next week. Marni Zollinger


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[email protected] <[email protected]> Thu, Jan 31, 2008 at 5:31 AM To: MarniJ Zollinger <[email protected]> Cc: Mark Alexander <[email protected]>, [email protected], Michael McCall <[email protected]>

Good Morning Marni: I am writing to let you know that I have discussed your questions with our consultants, and they have prepared a detailed response first and third question described below. We also discussed how to approach your second question; however, one of the problems we encountered when doing a baseline emissions profile of a landfill is that we don't have enough information to calculate a profile (gas curve) that would be meaningful. In the domestic United States, we typically we use the "First Order Decay" equation, which is contained in the AP-42 document described below as well as in the Project Development Handbook that I am attaching with this email. There are several variables involved in calculating a gas production curve, including: average annual waste acceptance rate, the number of years the landfill has been open, the number of years the landfill has been closed (if applicable), the potential of the waste to generate methane, and the rate of methane generation from the waste. These variables can vary widely depending on the site specific characteristics described above. We usually recommend that once you have some more of these specific numbers, you can go to LandGEM and develop a gas production curve. I am attaching one section of our Project Development Handbook, which describes the various methods for estimating



gas flow. Please see page 2-4 for details. If I can be of further assistance, please do not hesitate to contact me. Best Regards, Swarupa Ganguli, Program Manager EPA Landfill Methane Outreach Program (LMOP) Mail: USEPA (6207J), 1200 Pennsylvania Avenue, NW, Washington, DC 20460 Office: USEPA (6207J), 1310 L Street, NW, Washington, DC 20005 202-343-9732 (Phone), 202-343-2202 (Fax) (See attached file: hand_1.pdf) See below for answers to questions no. 1 and 3, prepared by our consultants. -------------------------------------------------------------------------------------------------------------------------------------------------- Dear Ms. Zollinger, We are happy to provide some general information in response to your questions. However, we would like to caution that if you are estimating emissions for regulatory purposes to determine if a landfill is subject to EPA's new source performance standards (NSPS) or emission guidelines, you must use the equation and procedures specified in the rule. These are found in the Code of Federal Regulations (CRF) at 40 CFR part 60 subpart WWW, section 60.754(a). [http://a257.g.akamaitech.net/7/257/2422/03jul20071500/edocket.access.gpo.gov/cfr_2007/julqtr/pdf/40cfr60.754.pdf]. If you are calculating emissions for purposes of selling GHG credits, you must follow the measurement and verification protocols required by the entity purchasing the credits. The EPA Climate Leaders Program, a voluntary GHG reduction partnership, has protocols for calculating baseline landfill GHG emissions [http://www.epa.gov/climateleaders/documents/resources/protocol-solid_waste_landfill.pdf] and methane reductions from landfill gas collection and combustion projects [http://www.epa.gov/climateleaders/documents/resources/draft_landfill_offset_protocol.pdf]. Various other organizations have also developed protocols to verify methane reductions from landfills. EPA's compilation of Air Pollutant Emission Factors (known as AP-42) also provides equations, default factors, and procedures for estimating landfill gas emissions [http://www.epa.gov/ttn/chief/ap42/ch02/bgdocs/b02s04.pdf]. EPA's Landfill Gas Emissions Model (LandGEM) is a user-friendly Excel model to implement the AP-42 calculations. The LandGEM model and User's Guide are available at http://www.epa.gov/ttn/catc/products.html#software . Regarding your specific questions: 1) A "rule of thumb" factor will not be sufficient for regulatory or GHG credit purposes, but as a rough estimate of how much methane may be generated from a ton of municipal solid waste placed in a landfill, LMOP uses a factor of 300 cubic feet of landfill gas per minute (cfm) per 1



million tons waste in place (WIP) in a MSW landfill. Landfill gas is generally 50% methane by volume. Of course, the emission rate depends on the waste composition, waste age, climate, landfill design and operating characteristics, etc. Regarding how many tons of methane might ultimately be generated from 1 ton of waste placed in a landfill, the default methane generation potential (Lo) used in EPA's compilation of air pollutant emission factors (AP-42) is 100 cubic meters of methane/Mg MSW (3,530 cubic feet of methane/ton of MSW placed in a landfill). This converts to 0.066 tons of methane per ton of MSW. As noted in AP-42, the value of Lo and the time (number of years) over which the methane is emitted will vary depending on many factors. This factor is for typical MSW landfills, which may contain other types of waste in addition to household waste. 3) EPA's LandGEM model and AP-42 emission estimation procedures (as well as the NSPS rules) use a first order decay model for landfill gas production. MSW landfills continue to produce emissions many years after the waste has been placed in a landfill. There is a gradual decline over time. In an arid area, where waste decays more slowly, the methane production would peak at a lower emission rate but would continue to be produced for more years than shown in this curve. In a very wet landfill or bioreactor, the peak emissions would be higher and then emissions would decline more quickly over a shorter number of years. "MarniJ Zollinger" <marnizollinger@ To cobcreations.com Swarupa Ganguli/DC/USEPA/US@EPA > cc Sent by: "Mark Alexander" marnizollinger2@ <[email protected]>, "Michael gmail.com McCall" <[email protected]> Subject 01/25/2008 07:02 Re: some baseline statistics PM needed


hand_1.pdf478K

MarniJ Zollinger <[email protected]> Thu, Jan 31, 2008 at 11:21 AM To: "[email protected]" <[email protected]> Cc: Mark Alexander <[email protected]>, Michael McCall <[email protected]>

Ms. Ganguli, I am very glad to receive this information! I will be reading what you have prepared very shortly. In answer to your question, the it appears, if I understood you correctly, that the datum that you are missing is



the period of TIME that the hypothetical landfill has been accepting 500 tpd? As the facility we are discussing which will DIVERT msw (that is the reason to get a ball park on emissions------ they are saved) is not meant to be constructed and shut down at year x, but instead to be constructed and renovated, refurbished, upgraded and improved perpetually, and there is no anticipation that population is going to decrease, 100+ years is reasonable but not likely to be envisionable by those participating today. So, please assume a landfill that has operated at 500 tpd for 25 years, and another that has operated at 500 tpd for ten years. If that is too much, please give ballpark figures for 10 years. I want to express how much we appreciate your hard work, Marni Zollinger


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[email protected] <[email protected]> Thu, Jan 31, 2008 at 12:59 PM To: MarniJ Zollinger <[email protected]> Cc: Mark Alexander <[email protected]>, [email protected], Michael McCall <[email protected]>

Dear Ms. Zollinger: I am glad you found the information I send you useful. From what I have discussed with my colleagues, it's very difficult to construct a model with just the few variables that you discussed; the only model that EPA has available for landfill gas estimation is called LandGEM, as I mentioned in my email. I will be out of the office tomorrow, but will be back by next week and see if I can get another answer to your question. If you have any other questions after reviewing the material that I sent you, I would be happy to talk to you again. Swarupa Ganguli, Program Manager EPA Landfill Methane Outreach Program (LMOP) Mail: USEPA (6207J), 1200 Pennsylvania Avenue, NW, Washington, DC 20460 Office: USEPA (6207J), 1310 L Street, NW, Washington, DC 20005 202-343-9732 (Phone), 202-343-2202 (Fax) "MarniJ Zollinger" <marnizollinger@ To cobcreations.com Swarupa Ganguli/DC/USEPA/US@EPA > cc Sent by: "Mark Alexander" marnizollinger2@ <[email protected]>, "Michael gmail.com McCall" <[email protected]> Subject 01/31/2008 02:21 Re: some baseline statistics




epa emissions rule of thumb

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