1. Greenhouse Gas (GHG) Permit Training PSD Applicability Example Landfill Applicability Examples John Calcagni, EPA Region 4

2. GHG Applicability Example

3. 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. DRAFT3

4. GHG Applicability in More Detail: Example Calculations (cont’d) Unit #1 The baseline actual emissions were determined from the prior ten years. DRAFT4 YearCO 2 MethaneMass TotalCO 2 e Total 1450955452,445 23851004852,485 3390954852,385 44101055152,615 5380954752,375 64101005102,510 7420955152,415 8420955152,415 9410905002,300 10450855352,235

5. GHG Applicability in More Detail: Example Calculations (cont’d) Unit #1 Applicant selected years 3 and 4 for the baseline actual emissions. Average emissions for those two years are: – CO 2 : 400 TPY – Methane:100 TPY – GHG Mass Total:500 TPY – GHG CO 2 e Total: 2,500 TPY DRAFT5

6. GHG Applicability in More Detail: Example Calculations (cont’d) Unit #1 Future actual emissions are forecast to be 450 TPY of CO 2 and 10 TPY of CH 4. Modification of existing Unit #1 will result in a CO 2 emissions increase of 50 TPY and a CH 4 emissions decrease of 90 TPY DRAFT6

7. GHG Applicability in More Detail: Example Calculations (cont’d) Unit #1 The pre- and post-change emissions are: Mass Based Calculations: – Baseline actual GHG emissions: 400 TPY(CO 2 ) +100 TPY(CH 4 ) = 500 TPY GHGs – Proposed GHG emissions after the change: 450 TPY(CO 2 ) +10 TPY(CH 4 ) = 460 TPY GHGs – Results in a decrease of 40 TPY GHGs, on a mass basis. DRAFT7

8. GHG Applicability in More Detail: Example Calculations (cont’d) Unit #1 CO 2 e Based Calculations: – Baseline actual CO 2 e emissions: (1 x 400 TPY CO 2 ) + (21 x 100 TPY CH 4 ) = 2,500 TPY CO 2 e. – Proposed CO 2 e emissions after the change: (1 x 450 TPY CO 2 ) + (21 x 10 TPY CH 4 ) = 660 TPY CO 2 e. – Results in a decrease of 1,840 TPY on a CO 2 e basis DRAFT8

9. GHG Applicability in More Detail: Example Calculations (cont’d) Unit #2 A new emissions unit with proposed emissions increase of 77,000 TPY of CO 2 (1 x 77,000 TPY CO 2 = 77,000 TPY CO 2 e). 1 Unit A Three years ago, during the contemporaneous period, there was an emissions increase of 10,000 TPY CO 2 (10,000 TPY CO 2 e) from the addition of this unit. There are no other creditable emissions increases or decreases during the contemporaneous period DRAFT9 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

10. GHG Applicability in More Detail: Example Calculations (cont’d) Mass-Based Calculations Step 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 DRAFT10

11. GHG Applicability in More Detail: Example Calculations (cont’d) 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 CO 2 e. DRAFT11

12. GHG Applicability in More Detail: Example Calculations (cont’d) CO 2 e-Based Calculations Step 1: In this step only consider units with CO 2 e emissions increases: Unit #2 77,000 TPY CO 2 e emissions increase. Unit #1 1,840 TPY CO 2 e emissions decrease. Total of increases = 77,000 TPY CO 2 e emissions increase from Unit #2. Because this is equal to or greater than 75,000 TPY CO 2 e, go to Step 2 and conduct contemporaneous netting DRAFT12

13. GHG Applicability in More Detail: Example Calculations (cont’d) Step 2: In this step, increases and decreases of CO 2 e from the proposed project and all other contemporaneous and creditable emissions increases and decreases of CO 2 e are summed. Net emissions increase (CO 2 e basis): 77,000 TPY CO 2 e (Unit #2) - 1,840 TPY CO 2 e (Unit #1) +10,000 TPY CO 2 e (Unit A) = 85,160 TPY CO 2 e emissions. This net emissions increase is equal to or greater than 75,000 TPY CO 2 e. Results: The modification is both a “significant emissions increase” (Step 1) and a “significant net emissions increase” (Step 2) in both the mass and CO 2 e-based calculations; therefore, the modification, as proposed, is subject to PSD for GHGs. DRAFT13

14. GHG Applicability in More Detail: Example Calculations (cont’d) 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 CO 2 e below 75,000 TPY In that instance the project increase would be less than 75,000 TPY CO 2 e and contemporaneous increases and decreases would not need to be considered. DRAFT14

15. Landfill PSD Applicability Examples

16. 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. DRAFT16

17. Landfill PSD Applicability Examples (cont’d) Determine PSD Applicability Step 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: CH 4 = 3,768 tons/yr CO 2 = 10,340 tons/yr NMOC = 24 tons/yr DRAFT17

18. 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 DRAFT18

19. Landfill PSD Applicability Examples (cont’d) Step 1: (cont’d) The PTE of GHG (in terms of CO 2 e), to compare to “subject to regulation” threshold, can be calculated as: PTE of GHG (tons CO 2 e/yr) = CH 4 generation x 21 + CO 2 generation = 3,768 tons/yr x 21 + 10,340 tons/yr = 89,468 tons CO 2 e/yr DRAFT19

20. Landfill PSD Applicability Examples (cont’d) 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) = CH 4 generation + CO 2 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 DRAFT20

21. Landfill PSD Applicability Examples (cont’d) Step 2: PSD Applicability Determination Based on the emissions calculated in Step 1, the PTE of Landfill A is listed in the table below DRAFT21 PollutantGHG (tons CO 2 e/yr) GHG (tons/yr) VOC (tons/yr) PTE of Landfill A 89,46814,10424 Subject to Regulation/PSD Major Source Thresholds 100,000250

22. Landfill PSD Applicability Examples (cont’d) 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) DRAFT22

23. Landfill PSD Applicability Examples 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. DRAFT23

24. Landfill PSD Applicability Examples (cont’d) Determine PSD Applicability Step 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: – CH 4 = 4,625 tons/yr – CO 2 = 12,689 tons/yr – NMOC = 30 tons/yr DRAFT24

25. Landfill PSD Applicability Examples (cont’d) Step 1: (cont’d) The PTE of GHG (in terms of CO 2 e), to compare to “subject to regulation” threshold, can be calculated as: PTE of GHG (tons CO 2 e/yr) = CH 4 generation x 21 + CO 2 generation = 4,625 tons/yr x 21 + 12,689 tons/yr = 109,814 tons/yr DRAFT25

26. Landfill PSD Applicability Examples (cont’d) 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) = CH 4 generation + CO 2 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 DRAFT26

27. Landfill PSD Applicability Examples (cont’d) Step 2: PSD Applicability Determination Based on the emissions calculated in Step 1, the PTE of Landfill B is: DRAFT27 PollutantGHG (tons CO 2 e/yr) GHG (tons/yr) VOC (tons/yr) PTE of Landfill B 109,81417,31430 Subject to Regulation/PSD Major Source Thresholds/Sig. Emission Rate 100,00025040

28. Landfill PSD Applicability Examples (cont’d) Step 3: PSD Applicability Determination The construction is subject to PSD for GHGs only because: – PTE of GHG in CO 2 e 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) DRAFT28

29. Landfill PSD Applicability Examples 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. DRAFT29

30. Landfill PSD Applicability Examples (cont’d) Determine PSD Applicability Step 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) DRAFT30

31. Landfill PSD Applicability Examples (cont’d) 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. DRAFT31 PollutantGHG (tons CO 2 e/yr) GHG (tons/yr) VOC (tons/yr) PTE of the Existing Landfill 81,34512,82522 Subject to Regulation/PSD Major Source Thresholds 100,000250

32. Landfill PSD Applicability Examples (cont’d) 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 DRAFT32 PollutantGHG (tons CO 2 e/yr) GHG (tons/yr) VOC (tons/yr) PTE of the new landfill 122,01919,23933 Subject to Regulation/PSD Major Source Thresholds 100,00025040

33. Landfill PSD Applicability Examples (cont’d) Step 3: Determine PSD Applicability DRAFT33 This new cell is subject to PSD for GHGs only because: PTE of GHG in CO 2 e 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)