E Providing Environmental Technical Support Since 1989 C

/R Incorporated

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MEMORANDUM 

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-HQOAR-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 
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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 District1

, 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. 

 

1

 Revisiting BACT for Lean Burn Landfill Gas Fired Internal Combustion Engines, Bay Area Air Quality 

Management District, February 26, 2009. http://hank.baaqmd.gov/pmt/bactworkbook/white_paperlb_lfg_ice_bact_2-26-09_final.pdf 
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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.