How do flaring LFG and LFG energy projects compare with regard to controlling fugitive emissions?
The NSPS for MSW landfills requires that landfills above a specified size and emission level collect and control LFG emissions, measure and report emissions, and meet other operational standards. These landfills must install and operate a gas collection and control system per the design submitted to the appropriate air regulatory agency. Additionally, these landfills must conduct quarterly surface (fugitive) emission monitoring evaluations to determine if excessive amounts of fugitive organic gases are present. If a surface emission monitoring event shows elevated fugitive emissions, the landfill must adjust or modify its gas collection and control system to increase the amount of LFG recovered from the landfill and to meet the surface emission criteria required by the NSPS. These requirements are the same, regardless of whether LFG is flared or an LFG energy facility is present. Therefore, at landfills regulated by the NSPS, the presence of an LFG energy project does not have an effec