MEMORANDUM  SEQ CHAPTER \h \r 1    

TO:		Melanie King, EPA OAQPS/SPPD/ESG

FROM:	Bradley Nelson, EC/R, Inc.

DATE:		September 21, 2009

SUBJECT:	Summary of the September 15, 2009 Meeting with the Operators of
Landfill Gas Engines and the U.S. Environmental Protection Agency to
discuss the Proposed NESHAP for Existing Stationary Reciprocating
Internal Combustion Engines

1.0	INTRODUCTION

Several companies that operate landfill gas (LFG) engines requested this
meeting with EPA to discuss issues with the proposed national emission
standards for hazardous air pollutants (NESHAP) for existing stationary
reciprocating internal combustion engines (RICE).  This meeting summary
will be available in the docket for this rulemaking (Docket ID No.
EPA-HQ-OAR-2008-0708).  The proposed NESHAP for existing stationary RICE
was published in the Federal Register on March 5, 2009 (74 FR 9698).  

2.0	ATTENDEES

U.S. Environmental Protection Agency

Melanie King, OAQPS/SPPD/ESG

Michael Horowitz, OGC (by phone)

Swarupa Ganguli, Landfill Methane Outreach Program  (by phone)

Victoria Ludwig, Landfill Methane Outreach Program (by phone)

Landfill Gas Engine Operators

Mike LaFramboise, Landfill Energy Systems

Bill Deckert, Energy Developments Inc.

Mike Dae, Energy Developments Inc.

Steve King, PNGC Power

Dennis Plaster, Innovative Energy Systems

Pete Zeliff, Innovative Energy Systems

Ben Benson, Energyneering

William Song, Energyneering

Billy Malone

EC/R Incorporated (EPA Contractor)

Bradley Nelson 

3.0	SUMMARY OF MEETING

Industry representatives opened the meeting by stating that they
represent a small segment of the landfill gas-to-energy operators in the
U.S.  Industry had requested the meeting with EPA to help understand how
decisions regarding landfill gas engines were made for the proposed
rule.  EPA responded that the RICE NESHAP was promulgated in 2004 for
engines greater than 500 horsepower (HP) located at major sources.  In
that rule, EPA determined that the maximum achievable control technology
(MACT) floor for landfill gas engines was no control.  EPA noted that
the landfill gas engines were not exempt in that rule, but that there
were no emissions requirements.  EPA stated that in March 2007, the
courts ruled that “no control” MACT floors are not emission
standards, and required EPA to establish emission requirements for major
sources.  The ruling is commonly referred to by EPA as the Brick MACT
ruling.  Therefore, for this proposed rule, EPA was required to
establish emission requirements for the landfill gas engines less than
500 HP located at major sources.  EPA asked industry if landfill gas
engines are mainly located at areas sources or major sources.  Industry
responded that it varies and that the determining factor is the size of
the landfill.    

Industry representatives stated that the proposed carbon monoxide (CO)
emission limit (177 parts per million (ppm)) for landfill gas engines is
not achievable and that a CO emission standard similar to the spark
ignition NSPS of 610 ppm of CO would be more appropriate.  EPA stated
that the approach and criteria used to develop emission standards under
the NSPS program are different than those used for developing emission
standards under the NESHAP program.  EPA stated that it relied on the
test data from the emission database for determining the top 12 percent
for setting the MACT standard.  Industry responded that it cannot use
control technologies to reduce CO and indicated that there are no
landfill gas engines capable of achieving 177 ppm CO.  Industry further
stated that the only option would be to shut down the engines, which
would cause a problem with many facilities due to long term power
agreements.  Industry noted that Caterpillar and Jenbacher only
guarantee emissions for the first 100 hours of operation for landfill
gas engines.  Industry also referred to a study done by the Bay Area Air
Quality Management District, which determined based on source test
results and operator experience that it is impractical to expect
reductions in both nitrogen oxides (NOX) and CO emission levels
simultaneously, without the use of downstream controls.  Therefore, if
engines are turned to achieve low CO emissions, the emissions of NOX
increase beyond NOX permit limits, according to industry.

Industry asked EPA if only 12 percent of the landfill gas engine can
achieve the proposed 177 ppm CO limit, how are the other 88 percent of
landfill gas engines expected to comply with this standard.  EPA
responded that it is required by Congress to establish the standards
based on the requirements in the Clean Air Act.  EPA can, however,
consider variability when setting the emission standards.  EPA also
stated that it could consider management practice standards for engines
greater than 500 HP at area sources.  For engines less than 500 HP
located at area sources, EPA required management practices in the
proposed rule.  The already promulgated 2004 NESHAP has no emission
requirements for landfill gas engines greater than 500 HP located at
major sources.  However, EPA noted that the promulgated RICE NESHAP will
be reviewed in 2012.  EPA recommended that industry provide new test
data to show the current emissions from landfill gas engines.  EPA also
asked industry to provide information on management practice standards
for landfill gas engines.  EPA stated that the management practice
standards must measurable and enforceable.  

EPA stated that it would need the management practice information and
test data by the end of September to be able to include the information
in the final rule, which is scheduled to be signed on February 10, 2010.
 EPA also stated that it would look at the variability of CO emissions
from the landfill gas engines.  Industry stated that most engines are
overhauled before the compliance tests, and that the reported emissions
should be considered as the best case scenario.  

 Revisiting BACT for Lean Burn Landfill Gas Fired Internal Combustion
Engines, Bay Area Air Quality Management District, February 26, 2009.  
HYPERLINK
"http://hank.baaqmd.gov/pmt/bactworkbook/white_paper-lb_lfg_ice_bact_2-2
6-09_final.pdf" 
http://hank.baaqmd.gov/pmt/bactworkbook/white_paper-lb_lfg_ice_bact_2-26
-09_final.pdf  

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

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