Air Quality Compliance for Landfill Gas-to-Energy Projects

摘要

As the landfill industry maneuvers its way through the maze of air quality regulations, one of the most confusing aspects of these regulations is how landfill gas-to-energy facilities are impacted. Over the last 5 years, as the New Source Performance Standards (NSPS/EG), Title V and other regulatory requirements have been implemented for landfills, there have been a series of inconsistent interpretations and rulings made by U.S. Environmental Protection Agency (EPA) and other agencies regarding the regulation of gas-to-energy facilities. The problem that will be addressed in this paper centers on an issue we call the "third party" issue. The third party issue refers to landfill sites where in addition to the site owner, other aspects of the landfill operations (e.g., landfill gas-to-energy facility, gas collection system) have subdivided ownership and/or operators; a common practice in the industry. This issue presents uncertainty for landfill gas-to-energy projects attempting to move forward in a regulatory environment that can bring significant liability to all parties if appropriate compliance objectives are not met. We will explore in this paper the third party issue as it impacts NSPS/EG and Title V compliance for landfill gas-to-energy facilities. The approach will be to first review the applicable regulations, then provide both the industry and regulatory perspective of the issues as well as explore potential solutions.