Head Start

Joel Miller and Cami Van Abel

As the old saying goes, an ounce of prevention is worth a pound of cure. This sentiment is likely to ring true with the implementation of the Environmental Protection Agency's (EPA) recently issued Mandatory Greenhouse Gas Reporting Rule (MRR). The rule affects several industries, but landfill owners and operators in particular should take note because 1) MRR is the first federal reporting requirement for landfill emissions since the New Source Performance Standards were enacted in 1996, and 2) the reported emissions will provide reference data that may be used in future greenhouse gas emission legislation.

Rule Requirements

MRR requires the monitoring, calculating and reporting of greenhouse gas emissions at landfills whether or not landfill gas is collected at the site. It applies to both open and closed municipal solid waste landfills that accepted waste after Jan. 1, 1980, and that generate methane in amounts equivalent to a minimum of 25,000 metric tons of carbon dioxide equivalent per year. Affected facilities were required to begin monitoring for parameters included in the rule on Jan. 1, 2010, and to report 2010 greenhouse gas emissions by March 31, 2011. In addition, landfill owners must develop and maintain an on-site monitoring plan to document equipment and operational practices. Although the monitoring plan does not need to be submitted to EPA, it must be updated as needed and kept on-site. Landfills may use best available monitoring methods (BAMM) to collect the required data until April 1, 2010, at which time strict compliance with the collection methodology is required, unless EPA grants the facility a BAMM extension variance.

As municipal solid waste landfill owners and operators determine if the rule is applicable to their landfills and what it means for their facilities, the Apri1 1 BAMM period end date is quickly approaching. In order to document applicability and establish monitoring practices compliant with MRR, facilities subject to the rule may benefit from establishing and implementing a monitoring plan in advance of the BAMM end date. This will allow facilities to establish monitoring practices, ensure installation of the proper monitoring equipment and ease compliance with MRR plan requirements.

Developing the Monitoring Plan

Specific requirements for the onsite monitoring plan are detailed in MRR, but landfill owners and operators should consider their current monitoring operations, equipment and staff capabilities when preparing these plans. The plan should clearly delineate responsibilities and should be updated and maintained as a “living” document as staff and facility operational changes occur. It can complement existing standard operating procedures and may not require additional monitoring efforts (this is especially true for sites pursuing carbon offset credits or monitoring efforts for landfill gas-to-energy projects).

Verify that equipment at the facility complies with MRR specifications and that monitoring staff are adequately trained in accordance with equipment manufacturer specifications. Familiarize yourself with equipment calibration schedules and maintain the proper documentation for calibration events.

Beyond the basic monitoring requirements, facility owners or operators may want to take the opportunity to document the applicability of MRR to their facility and what calculation methodologies they use. Should the facility later become exempt from the reporting, or if the facility installs a gas collection and control system (which may subject it to other MRR calculation methodologies), the plan can be updated fairly simply.

The monitoring plan that is kept on site should reflect current landfill operations. Any facility modifications that affect the calculation methodology used to report GHG emissions should be clearly noted in the plan.

EPA has published rule clarifications and guidance in the form of flowcharts and "frequently asked questions." The monitoring plan is likely an attempt by EPA to promote early action on MRR and encourage responsible record-keeping. Taking initiative will benefit facilities by granting them time to determine what works for their operations, decreasing the amount of last-minute questions and improving the quality of the data compiled by March 2011, when 2010 data is due.

Executing the Monitoring Plan

Finally, a well-written monitoring plan must be properly executed. Facility staff should be clearly aware of their responsibilities and should know whom to contact when issues arise. Use the opportunity to work out any unexpected scheduling, staffing, equipment or monitoring issues. In addition, if monitoring equipment needs to be specified, ordered or installed to comply with MRR, early implementation provides time to train staff on operation, quality assurance and quality control procedures.

Similar to changes in facility operations or monitoring requirements, early preparation is key to a facility's success. Establishing and implementing a site specific plan will ease the burden of MRR reporting efforts in 2011.

Notice: This is not a full analysis of the Mandatory Greenhouse Gas Reporting Rule and should not be relied upon as legal advice. It is a summary provided solely for general informational purposes. For additional information, you can access the entire text of the final rule on EPA's Web site by visiting www.epa.gov/climatechange/emissions/ghgrulemaking.html.

At a Glance: Monitoring Plan

A well-developed monitoring plan will:

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Joel Miller, P.E., is a project manager and landfill gas specialist for the solid waste practice of R. W. Beck, an SAIC company. Cami Van Abel, P.E., is an associate for R. W. Beck, an SAIC company.