The obvious fixes to EPA landfill regulations
On May 18, Environmental Integrity Project (EIP) released a report, Trashing the Climate: Methane from Municipal Landfills, detailing the incredible amount of landfill methane emissions, and the need to better regulate those emissions. Landfilled organic waste—food, paper and yard—generates methane under anaerobic conditions. The vast majority of emissions come from open or active municipal solid waste (MSW) landfills. Methane generation depends on a number of factors like the climate (more rain can lead to more methane generation), type and composition of waste, age of waste, amount of waste-in-place (current waste in the landfill) and the moisture content within the landfill. Conditions are always changing at an active landfill, which means good management requires both constant vigilance to detect leaks and well-designed and well-operated systems.
Read the full report here.
Key takeaways from the report:
Stronger federal rules for municipal landfills are necessary to curtail methane emissions. EIP points out a number of deficiencies in EPA regulation, and how to improve that regulation.
Some states have already vetted and implemented regulations that better manage methane emissions. The EPA sets the regulatory floor, and states have a parallel authority—and responsibility— to set regulations. California and Oregon have already issued stronger rules for landfills, and as of last week, California is considering significant improvements to its rules based on what it has learned over the past 10 years. Maryland issued draft rules that are close to being finalized, and Washington is up next, having started a rulemaking process to implement a law requiring the state environmental agency to issue regulations.
Here’s a run-down of the lowest hanging fruit on the tree, e.g. regulations already in states, that the EPA could pick:
Institute lower thresholds for the installation of gas collection and control systems, more closely tied to gas production. Analyzing admittedly voluntarily reported and incomplete data provided to the EPA, about 40% of all U.S. active municipal landfills do not have gas capture systems in place. Gas control systems collect landfill gas and dispose of it or treat it, using devices including enclosed flares, fuel cells, and combustion engines. EIP states, “All rules for the control of landfill emissions—either at the state or federal level—take the general approach of requiring installation of a gas collection and control system for landfills that meet certain size or emissions thresholds. However, states have set lower thresholds, requiring gas controls at smaller landfills. The states of Oregon, California, and Washington all use lower thresholds than EPA’s that are more closely tied to whether a landfill produces enough gas to operate controls.”
Ensure installation of the gas collection and control system in a timely manner so the maximum amount of methane is captured: don’t wait 7 years!: Current federal rules allow more than seven years to pass before a gas collection and control system needs to be up and running on a landfill expansion. But EIP argues, “In fact, ‘early’ collection of landfill gas, within a few months of waste placement, plays a critical role in reducing emissions and odors. Further, methane emissions could be reduced at newly constructed landfills by requiring that collection systems be designed and planned from the beginning, e.g., alongside considering the initial liner requirements.”
Up-to-date, rigorous operational standards for landfill gas collection and control systems. Several states already have more effective operational standards in place than the EPA. As EIP notes, “Among other things, these standards require higher combustion efficiencies at flares, and the monitoring and repair of on-site equipment for gas leaks. California and Oregon require the phase-out of open flares for the combustion of landfill gas. Open flares operate less efficiently than enclosed flares and are more difficult to monitor. The states also require flares at landfills to meet a performance requirement of 99 percent methane destruction efficiency in lieu of EPA’s rule requiring 98 percent destruction efficiency tied to a group of pollutants called nonmethane organic compound.”
Actually check the gas collection and control system for leaks and fix the leaks: Checking positive pressure systems for leaks is a common sense approach. EIP states, “EPA’s current regulations include no equipment leak detection or control requirements at all for municipal landfills. Leak detection and repair is the process by which sources of air pollution can detect and correct leaking components. Leaking equipment, such as valves, pumps, and connectors, are a large source of methane as well as emissions of volatile organic compounds and hazardous air pollutants, also known as air toxics. Leaks can occur from the collection system components of the landfill and through the landfill itself on the surface. Leak detection and repair has been increasingly recognized by EPA as an effective practice for controlling fugitive gas leaks from equipment used in the petrochemical sector. California and Oregon regulations establish leak detection requirements for reducing emissions from leaks in control equipment at landfills. EPA’s regulations do not require leak detection from these systems.”
Finally, EIP notes that other effective methods of reducing methane from landfills, beyond what is in current state regulation, that are important—and it’s worth noting that the California Air Resources Board flagged some of the same measures as potential improvements to their regulations:
Super-emitter monitoring and response: EIP states that “Advancements in emissions monitoring focused on methane have been incorporated into EPA’s recently proposed new rules for the oil and gas industry… In these rules EPA establishes programs for identifying and correcting leaks from oil and gas equipment as well as leaks so big that they qualify facilities as “super emitters.” EPA requires leak monitoring on a periodic or continuous basis, which will provide more representative data than the quarterly sampling that is currently required for landfills. These programs should be replicated in new regulations for landfills.”
Close the “cover loophole”: EIP states that the “type of cover that is placed on top of waste in a landfill can remove a substantial amount of methane before it enters the air through a process called ‘oxidation.’ Cover can also boost the efficiency of gas collection systems. Landfill cover is primarily regulated under solid waste disposal laws however, and not under laws for the control of air pollution.” EIP adds: “Final cover, which is typically thicker and less permeable than daily cover, is generally not installed until the entire landfill has reached capacity or the facility has stopped receiving waste. However, if final cover is installed incrementally onto parts of the landfill that have reached their final contours, this can help to minimize methane emissions.” Ultimately, “The EPA should require landfill operators to maintain and implement an EPA-approved landfill cover design plan that addresses air pollution.”
Encourage the most effective way to stop methane emissions—don’t put the organic waste in the landfill in the first place. EIP notes, “Because landfill gas is formed by the decomposition of organic material in the waste at landfills, part of a comprehensive approach to reducing greenhouse gasses from landfills is keeping organic material, like yard waste and food scraps, out of landfills in the first place…The EPA has estimated that composting and anaerobic digestion can each achieve a 95 percent methane reduction efficiency when compared to landfilling organic waste.”
The EPA has the power and responsibility to regulate methane from landfills, and can use state regulations as vetted examples.
