Greenhouse Gas (GHG) Permit Training PSD Applicability Example Landfill Applicability Examples John...

Greenhouse Gas (GHG) Permit Training

PSD Applicability ExampleLandfill Applicability Examples

John Calcagni, EPA Region 4

GHG Applicability Example

GHG Applicability in More Detail: Example Calculations

Example Scenario:• An existing stationary source is major for PSD for

another pollutant and a new modification involving GHGs may be major and possibly subject to PSD.

• The proposed modification consists of:– The modification of an existing unit (Unit #1) and– The addition of a new emissions unit (Unit #2).

• Emissions Unit A was added three years ago.

DRAFT 3

GHG Applicability in More Detail: Example Calculations (cont’d)

Unit #1 The baseline actual emissions were determined from the prior ten years.

DRAFT 4

Year CO2 Methane Mass Total CO2e Total

1 450 95 545 2,445

2 385 100 485 2,485

3 390 95 485 2,385

4 410 105 515 2,615

5 380 95 475 2,375

6 410 100 510 2,510

7 420 95 515 2,415

8 420 95 515 2,415

9 410 90 500 2,300

10 450 85 535 2,235


Unit #1• Applicant selected years 3 and 4 for the baseline

actual emissions.• Average emissions for those two years are:

– CO2: 400 TPY

– Methane: 100 TPY– GHG Mass Total: 500 TPY– GHG CO2e Total: 2,500 TPY

DRAFT 5


Unit #1• Future actual emissions are forecast to be 450 TPY of

CO2 and 10 TPY of CH4.

• Modification of existing Unit #1 will result in a CO2

emissions increase of 50 TPY and a CH4 emissions decrease of 90 TPY

DRAFT 6


Unit #1The pre- and post-change emissions are:

Mass Based Calculations:– Baseline actual GHG emissions: 400 TPY(CO2 ) +100 TPY(CH4) = 500 TPY GHGs

– Proposed GHG emissions after the change: 450 TPY(CO2) +10 TPY(CH4) = 460 TPY GHGs

– Results in a decrease of 40 TPY GHGs, on a mass basis.

DRAFT 7


Unit #1CO2e Based Calculations:

– Baseline actual CO2e emissions:

(1 x 400 TPY CO2) + (21 x 100 TPY CH4) = 2,500 TPY CO2e.

– Proposed CO2e emissions after the change:

(1 x 450 TPY CO2) + (21 x 10 TPY CH4) = 660 TPY CO2e.

– Results in a decrease of 1,840 TPY on a CO2e basis

DRAFT 8


Unit #2 A new emissions unit with proposed emissions increase of 77,000 TPY of CO2 (1 x 77,000 TPY CO2 = 77,000 TPY CO2e).1

Unit A Three years ago, during the contemporaneous period, there was an emissions increase of 10,000 TPY CO2 (10,000 TPY CO2e) from the addition of this unit. There are no other creditable emissions increases or decreases during the contemporaneous period

DRAFT 9

1 For the purposes of this example, the GWP values are from the 40 CFR Part 98 Table A-1, as of the date of this document


Mass-Based CalculationsStep 1: In this step only consider units with emissions

increases of GHGs from the proposed modification• Unit #2 77,000 TPY mass emissions increase of GHGs.• Unit #1 The change at Unit #1 results in a decrease in

GHG emissions and is therefore not considered in Step 1.• Increases = 77,000 TPY GHG mass-based emissions.• Because this increase is greater than zero TPY, one

conducts contemporaneous netting

DRAFT 10


Step 2: In this step, the creditable emissions increases and decreases of GHGs from the project and all other contemporaneous and creditable emissions increases and decreases of GHGs are summed.•Net emissions increase (mass based) = 77,000 TPY (Unit #2) - 40 TPY (Unit #1) +10,000 TPY (Unit A) = 86,960 TPY GHG mass emissions.•Because this net emissions increase is greater than zero TPY, one carries out the same steps using CO2e.

DRAFT 11


CO2e-Based Calculations

Step 1: In this step only consider units with CO2e emissions increases:

• Unit #2 77,000 TPY CO2e emissions increase.

• Unit #1 1,840 TPY CO2e emissions decrease.

• Total of increases = 77,000 TPY CO2e emissions increase from Unit #2.

• Because this is equal to or greater than 75,000 TPY CO2e, go to Step 2 and conduct contemporaneous netting

DRAFT 12


Step 2: In this step, increases and decreases of CO2e from the proposed project and all other contemporaneous and creditable emissions increases and decreases of CO2e are summed.

•Net emissions increase (CO2e basis): 77,000 TPY CO2e (Unit #2)

- 1,840 TPY CO2e (Unit #1) +10,000 TPY CO2e (Unit A) = 85,160 TPY CO2e emissions.

•This net emissions increase is equal to or greater than 75,000 TPY CO2e.•Results: The modification is both a “significant emissions increase” (Step 1) and a “significant net emissions increase” (Step 2) in both the mass and CO2e-based calculations; therefore, the modification, as proposed, is subject to PSD for GHGs.

DRAFT 13


Alternative Outcome: • The applicant could take enforceable limits to reduce

the net increase below the threshold in any of the four tests.

• In this instance, the simplest approach would be to agree to take a limit on Unit #2 CO2e below 75,000 TPY

• In that instance the project increase would be less than 75,000 TPY CO2e and contemporaneous increases and decreases would not need to be considered.

DRAFT 14

Landfill PSD Applicability Examples


Example 1• Company X1 is planning to construct an entirely new

MSW landfill (Landfill A) in 2012 with a capacity of 2.2 million Mg (= 2.42 million short tons).

• This landfill will be located in an attainment area for all NSR regulated pollutants.

• The lifespan of Landfill A is expected to be 30 years.

DRAFT 16

Landfill PSD Applicability Examples (cont’d)

Determine PSD ApplicabilityStep 1:• Determine the PTE of the new landfill assuming waste

acceptance is evenly distributed over the 30-year lifetime.

• Waste Acceptance Rate = 2,200,020 Mg / 30 years = 73,333 Mg/yr

The LandGEM results for 2042 are:• CH4 = 3,768 tons/yr• CO2 = 10,340 tons/yr• NMOC = 24 tons/yr

DRAFT 17

What is LandGEM?

• Excel-based software based on a first-order decomposition rate equation

• Quantifies emissions from the decomposition of landfilled waste in municipal solid waste (MSW) landfills

• Provides a relatively simple approach to estimating landfill gas emissions

• http://www.epa.gov/ttn/catc/products.html#software

DRAFT 18

http://www.epa.gov/ttn/catc/products.html


Step 1: (cont’d)• The PTE of GHG (in terms of CO2e), to compare to

“subject to regulation” threshold, can be calculated as:

• PTE of GHG (tons CO2e/yr)= CH4 generation x 21 + CO2 generation

= 3,768 tons/yr x 21 + 10,340 tons/yr= 89,468 tons CO2e/yr

DRAFT 19


Step 1: (cont’d)• The PTE of GHG (on a mass-basis), to compare to the PSD

major source threshold, can be calculated as:• PTE of GHG (tons/yr)

= CH4 generation + CO2 generation

= 3,768 tons/yr + 10,340 tons/yr= 14,104 tons /yr

• Assuming 100% of NMOC emissions are VOC emissions, then:PTE of VOC = PTE of NMOC = 24 tons/yr

DRAFT 20


Step 2: PSD Applicability Determination• Based on the emissions calculated in Step 1, the PTE

of Landfill A is listed in the table below

DRAFT 21

Pollutant GHG(tons CO2e/yr)

GHG(tons/yr)

VOC(tons/yr)

PTE of Landfill A 89,468 14,104 24

Subject to Regulation/PSD Major Source

Thresholds

100,000 250 250


Step 3: PSD Applicability Determination• The construction of this new landfill is not subject to

PSD because:– PTE for GHG from the new landfill is less than the PSD

subject to regulation threshold (100,000 TPY)and

– PTE for VOC is less than the major source threshold (250 TPY)

DRAFT 22


Example 2• Company X2 is planning to construct an entirely new

MSW landfill (Landfill B) in 2012 with a capacity of 2.7 million Mg (= 2.97 million short tons).

• This landfill will be located in an attainment area for all NSR regulated pollutants.

• The lifespan of the landfill is expected to be 30 years.

DRAFT 23


Determine PSD ApplicabilityStep 1:• Determine the PTE of the new landfill assuming waste

acceptance is evenly distributed over the 30-year lifetime

• Waste Acceptance Rate = 2,700,000 Mg / 30 years = 90,000 Mg/yr

The LandGEM results for 2042 are:– CH4 = 4,625 tons/yr– CO2 = 12,689 tons/yr– NMOC = 30 tons/yr

DRAFT 24


Step 1: (cont’d)• The PTE of GHG (in terms of CO2e), to compare to

“subject to regulation” threshold, can be calculated as:

• PTE of GHG (tons CO2e/yr)= CH4 generation x 21 + CO2 generation

= 4,625 tons/yr x 21 + 12,689 tons/yr= 109,814 tons/yr

DRAFT 25


Step 1: (cont’d)• The PTE of GHG (on a mass-basis), to compare to the

PSD major source threshold, can be calculated as:• PTE of GHG (tons/yr)

= CH4 generation + CO2 generation= 4,625 tons/yr + 12,689 tons/yr= 17,314 tons/yr

• Assuming 100% of NMOC emissions are VOC emissions, then:PTE of VOC = PTE of NMOC = 30 tons/yr

DRAFT 26


Step 2: PSD Applicability Determination• Based on the emissions calculated in Step 1, the PTE

of Landfill B is:

DRAFT 27


GHG(tons/yr)

VOC(tons/yr)

PTE of Landfill B 109,814 17,314 30


Thresholds/Sig. Emission Rate

100,000 250 40


Step 3: PSD Applicability Determination• The construction is subject to PSD for GHGs only

because:– PTE of GHG in CO2e from the new landfill is greater than

the PSD subject to regulation threshold (100,000 TPY) and greater than the major source threshold (250 TPY)and

– PTE for VOC is less than the significant emission rate (40 TPY)

DRAFT 28


Example 3: Expansion of Existing Landfill• Company X3 owns an existing MSW landfill with a maximum

capacity of 2.0 million Mg that was opened in 1985.• There is no collection and control system installed within the

existing landfill.• The existing landfill is expected to close in 2015 and Company

X3 is planning to add a new MSW landfill cell in 2012 with a capacity of 3.0 million Mg next to the original landfill site.

• The lifespan of the new landfill cell is expected to be 30 years.• This landfill is located in an attainment area for all NSR

regulated pollutants.

DRAFT 29


Determine PSD ApplicabilityStep 1:• Determine the PTE for the existing landfill, assuming waste

acceptance is evenly distributed over the 30-year lifetime• Waste Acceptance Rate = 2,000,000 Mg / 30 years = 66,666.7

Mg/yr (66,667 was used for the first 20 years and 66,666 was used for the remaining 10 years)

DRAFT 30


Step 2: (cont’d)• Following the similar steps in Example 1, the PTE of the

existing 2.0 million Mg landfill can be estimated using LandGEM and the results are listed in the table below.

DRAFT 31


GHG(tons/yr)

VOC(tons/yr)

PTE of the Existing Landfill

81,345 12,825 22


Thresholds

100,000 250 250


Step 2: Determine the PTE of the new landfill cell• Following the similar steps in Example 2, the PTE of GHG and

VOC for the new 3.0 million Mg landfill cell can be estimated using LandGEM and the results are listed in the table below

DRAFT 32


GHG(tons/yr)

VOC(tons/yr)

PTE of the new landfill

122,019 19,239 33


Thresholds

100,000 250 40


Step 3: Determine PSD Applicability

DRAFT 33

This new cell is subject to PSD for GHGs only because:•PTE of GHG in CO2e from the new landfill is greater than the PSD subject to regulation threshold (100,000 TPY) and greater than the major source threshold (250 TPY)

and•PTE for VOC is less than the significant emission rate (40 TPY)

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