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MarniJ Zollinger <marnizollinger2@gmail.com>

some baseline statistics needed

6 messages

Wed, Jan 23, 2008 at 10:48

MarniJ Zollinger <marnizollinger@cobcreations.com>
AM
To: ganguli.swarupa@epa.gov
Cc: Michael McCall <worldwidecap@hotmail.com>, Mark Alexander <iffg777@msn.com>

Greetings again Ms. Swarupa,

We spoke on the phone a few days ago. I was interested in obtaining a general understanding of how federal
regulations were enforced for landfill emissions when de minimus levels of emissions appeared to be
regularly exceeded by landfill emissions at all times, if properly calculated over the lifetime greatest decay (25
years?). You were able to help me by offering basic calculations that are used for carbon credit emissions.

I have some general questions:

1. Can you please provide the rule of thumb emissions production in tons that are used per 1 ton, per 100
tons, and per 500 tons of class I (household) MSW?

2. Is it possible that you could obtain through your consultant contacts, a baseline emissions profile of a
landfill that accepts 500 tpd of Class I MSW, measuring the emissions in tons per year?

3. I have noticed that there are many models (with differing years of study-- some go out 20 years, others go
out 40 years) of projecting the MSW decay, can you provide me with the data for model of decay accepted by
the EPA for the purpose of calculating credits?
Many thanks,

Marni Zollinger, CEO

--
Cob Creations, LLC
(877) 300-0187 x 701
(801) 404-2759 direct cell
(309) 422-7653 fax
marnizollinger@cobcreations.com

Ganguli.Swarupa@epamail.epa.gov <Ganguli.Swarupa@epamail.epa.gov> Fri, Jan 25, 2008 at 1:39 PM

To: MarniJ Zollinger <marnizollinger@cobcreations.com>
Cc: Mark Alexander <iffg777@msn.com>, marnizollinger2@gmail.com, Michael McCall
<worldwidecap@hotmail.com>

Good afternoon, Marni. I have received your request and already

discussed an approach to answer your questions with our contracting
specialists. We will send you some preliminary answers by early next
week.

Regards,
Swarupa Ganguli, Program Manager
EPA Landfill Methane Outreach Program (LMOP)
Mail: USEPA (6207J), 1200 Pennsylvania Avenue, NW, Washington, DC 20460
Office: USEPA (6207J), 1310 L Street, NW, Washington, DC 20005
202-343-9732 (Phone), 202-343-2202 (Fax)

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"MarniJ
Zollinger"
<marnizollinger@ To
cobcreations.com Swarupa Ganguli/DC/USEPA/US@EPA
> cc
Sent by: "Michael McCall"
marnizollinger2@ <worldwidecap@hotmail.com>, "Mark
gmail.com Alexander" <iffg777@msn.com>
Subject
some baseline statistics needed
01/23/2008 01:48
PM
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MarniJ Zollinger <marnizollinger@cobcreations.com> Fri, Jan 25, 2008 at 4:02 PM

To: "Ganguli.Swarupa@epamail.epa.gov" <Ganguli.Swarupa@epamail.epa.gov>
Cc: Mark Alexander <iffg777@msn.com>, Michael McCall <worldwidecap@hotmail.com>

I thank you and your team. We look forward to that information next week.
Marni Zollinger

[Quoted text hidden]

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[Quoted text hidden]

Ganguli.Swarupa@epamail.epa.gov <Ganguli.Swarupa@epamail.epa.gov> Thu, Jan 31, 2008 at 5:31 AM

To: MarniJ Zollinger <marnizollinger@cobcreations.com>
Cc: Mark Alexander <iffg777@msn.com>, marnizollinger2@gmail.com, Michael McCall
<worldwidecap@hotmail.com>

Good Morning Marni:

I am writing to let you know that I have discussed your questions with
our consultants, and they have prepared a detailed response first and
third question described below. We also discussed how to approach your
second question; however, one of the problems we encountered when doing
a baseline emissions profile of a landfill is that we don't have enough
information to calculate a profile (gas curve) that would be meaningful.
In the domestic United States, we typically we use the "First Order
Decay" equation, which is contained in the AP-42 document described
below as well as in the Project Development Handbook that I am attaching
with this email. There are several variables involved in calculating a
gas production curve, including: average annual waste acceptance rate,
the number of years the landfill has been open, the number of years the
landfill has been closed (if applicable), the potential of the waste to
generate methane, and the rate of methane generation from the waste.
These variables can vary widely depending on the site specific
characteristics described above. We usually recommend that once you have
some more of these specific numbers, you can go to LandGEM and develop a
gas production curve. I am attaching one section of our Project
Development Handbook, which describes the various methods for estimating

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gas flow. Please see page 2-4 for details.

If I can be of further assistance, please do not hesitate to contact me.

Best Regards,
Swarupa Ganguli, Program Manager
EPA Landfill Methane Outreach Program (LMOP)
Mail: USEPA (6207J), 1200 Pennsylvania Avenue, NW, Washington, DC 20460
Office: USEPA (6207J), 1310 L Street, NW, Washington, DC 20005
202-343-9732 (Phone), 202-343-2202 (Fax)
(See attached file: hand_1.pdf)

See below for answers to questions no. 1 and 3, prepared by our

consultants.
-------------------------------------------------------------------------------------------------------------------------------------------------
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Dear Ms. Zollinger,

We are happy to provide some general information in response to your

questions.

However, we would like to caution that if you are estimating emissions

for regulatory purposes to determine if a landfill is subject to EPA's
new source performance standards (NSPS) or emission guidelines, you must
use the equation and procedures specified in the rule. These are found
in the Code of Federal Regulations (CRF) at 40 CFR part 60 subpart WWW,
section 60.754(a).
[http://a257.g.akamaitech.net/7/257/2422/03jul20071500/edocket.access.gpo.gov/cfr
_2007/julqtr/pdf/40cfr60.754.pdf].

If you are calculating emissions for purposes of selling GHG credits,

you must follow the measurement and verification protocols required by
the entity purchasing the credits. The EPA Climate Leaders Program, a
voluntary GHG reduction partnership, has protocols for calculating
baseline landfill GHG emissions
[http://www.epa.gov/climateleaders/documents/resources/protocol-solid_waste_landfill.pdf]

and methane reductions from landfill gas collection and combustion

projects
[http://www.epa.gov/climateleaders/documents/resources/draft_landfill_offset_protocol.pdf].

Various other organizations have also developed protocols to verify

methane reductions from landfills.

EPA's compilation of Air Pollutant Emission Factors (known as AP-42)

also provides equations, default factors, and procedures for estimating
landfill gas emissions
[http://www.epa.gov/ttn/chief/ap42/ch02/bgdocs/b02s04.pdf]. EPA's
Landfill Gas Emissions Model (LandGEM) is a user-friendly Excel model to
implement the AP-42 calculations. The LandGEM model and User's Guide are
available at http://www.epa.gov/ttn/catc/products.html#software .

Regarding your specific questions:

1) A "rule of thumb" factor will not be sufficient for regulatory or GHG

credit purposes, but as a rough estimate of how much methane may be
generated from a ton of municipal solid waste placed in a landfill, LMOP
uses a factor of 300 cubic feet of landfill gas per minute (cfm) per 1

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million tons waste in place (WIP) in a MSW landfill. Landfill gas is

generally 50% methane by volume. Of course, the emission rate depends on
the waste composition, waste age, climate, landfill design and operating
characteristics, etc.

Regarding how many tons of methane might ultimately be generated from 1

ton of waste placed in a landfill, the default methane generation
potential (Lo) used in EPA's compilation of air pollutant emission
factors (AP-42) is 100 cubic meters of methane/Mg MSW (3,530 cubic feet
of methane/ton of MSW placed in a landfill). This converts to 0.066 tons
of methane per ton of MSW. As noted in AP-42, the value of Lo and the
time (number of years) over which the methane is emitted will vary
depending on many factors. This factor is for typical MSW landfills,
which may contain other types of waste in addition to household waste.

3) EPA's LandGEM model and AP-42 emission estimation procedures (as well
as the NSPS rules) use a first order decay model for landfill gas
production. MSW landfills continue to produce emissions many years after
the waste has
been placed in a landfill. There is a gradual decline over time. In an
arid area, where waste decays more slowly, the methane production would
peak at a lower emission rate but would continue to be produced for more
years than shown in this curve. In a very wet landfill or bioreactor,
the peak emissions would be higher and then emissions would decline more
quickly over a shorter number of years.

"MarniJ
Zollinger"
<marnizollinger@ To
cobcreations.com Swarupa Ganguli/DC/USEPA/US@EPA
> cc
Sent by: "Mark Alexander"
marnizollinger2@ <iffg777@msn.com>, "Michael
gmail.com McCall"
<worldwidecap@hotmail.com>
Subject
01/25/2008 07:02 Re: some baseline statistics
PM needed
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hand_1.pdf
478K

MarniJ Zollinger <marnizollinger@cobcreations.com> Thu, Jan 31, 2008 at 11:21 AM

To: "Ganguli.Swarupa@epamail.epa.gov" <Ganguli.Swarupa@epamail.epa.gov>
Cc: Mark Alexander <iffg777@msn.com>, Michael McCall <worldwidecap@hotmail.com>

Ms. Ganguli,

I am very glad to receive this information! I will be reading what you have prepared very shortly.

In answer to your question, the it appears, if I understood you correctly, that the datum that you are missing is

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the period of TIME that the hypothetical landfill has been accepting 500 tpd?

As the facility we are discussing which will DIVERT msw (that is the reason to get a ball park on emissions----
-- they are saved) is not meant to be constructed and shut down at year x, but instead to be constructed and
renovated, refurbished, upgraded and improved perpetually, and there is no anticipation that population is
going to decrease, 100+ years is reasonable but not likely to be envisionable by those participating today.

So, please assume a landfill that has operated at 500 tpd for 25 years, and another that has operated at 500
tpd for ten years. If that is too much, please give ballpark figures for 10 years.

I want to express how much we appreciate your hard work,

Marni Zollinger

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Ganguli.Swarupa@epamail.epa.gov <Ganguli.Swarupa@epamail.epa.gov> Thu, Jan 31, 2008 at 12:59 PM

To: MarniJ Zollinger <marnizollinger@cobcreations.com>
Cc: Mark Alexander <iffg777@msn.com>, marnizollinger2@gmail.com, Michael McCall
<worldwidecap@hotmail.com>

Dear Ms. Zollinger:

I am glad you found the information I send you useful. From what I have
discussed with my colleagues, it's very difficult to construct a model
with just the few variables that you discussed; the only model that EPA
has available for landfill gas estimation is called LandGEM, as I
mentioned in my email. I will be out of the office tomorrow, but will be
back by next week and see if I can get another answer to your question.
If you have any other questions after reviewing the material that I sent
you, I would be happy to talk to you again.

Swarupa Ganguli, Program Manager

EPA Landfill Methane Outreach Program (LMOP)
Mail: USEPA (6207J), 1200 Pennsylvania Avenue, NW, Washington, DC 20460
Office: USEPA (6207J), 1310 L Street, NW, Washington, DC 20005
202-343-9732 (Phone), 202-343-2202 (Fax)

"MarniJ
Zollinger"
<marnizollinger@ To
cobcreations.com Swarupa Ganguli/DC/USEPA/US@EPA
> cc
Sent by: "Mark Alexander"
marnizollinger2@ <iffg777@msn.com>, "Michael
gmail.com McCall"
<worldwidecap@hotmail.com>
Subject
01/31/2008 02:21 Re: some baseline statistics
[Quoted text hidden]

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