clinton landfill #2 gas collection and combustion clinton ... - clinton pdd v1.3... · clinton...

Clinton Landfill #2 Gas Collection and Combustion

Clinton, Illinois USA

PROJECT DESCRIPTION Version 1.3

March 12, 2009

VCS Project Description: Clinton Landfill Gas-to-Energy

TerraPass Confidential

Revision history

This document is based on the Voluntary Carbon Standard Project Description Template dated November 19, 2007.

Rev Date Author Description 0.8 Jan. 16, 2009 Adam Stein First draft for internal review. Final pre-Project

landfill gas flow figures still needed. 0.81 Jan. 20, 2009 Mark Frey Initial review. 1.0 Feb. 3, 2009 Adam Stein Ready for submission to validator. 1.1 Mar. 12, 2009 Adam Stein Changed crediting period start date to May 2009 1.3 May 20, 2009 Adam Stein Addressed first round of corrective action requests

and clarification requests



Contents 1 DESCRIPTION OF PROJECT..................................................................................................................4 2 VCS METHODOLOGY ............................................................................................................................14 3 MONITORING ...........................................................................................................................................29 4 GHG EMISSION REDUCTIONS............................................................................................................47 5 ENVIRONMENTAL IMPACT ................................................................................................................56 6 STAKEHOLDERS COMMENTS ...........................................................................................................57 7 SCHEDULE .................................................................................................................................................58 8 OWNERSHIP ..............................................................................................................................................59 ANNEX 1: KEY METHANE GENERATION INPUTS AND ASSUMPTIONS ....................................60 ANNEX 2: U.S. CLEAN AIR ACT DISCLOSURE REQUIREMENTS..................................................63 ANNEX 3: CLINTON LANDFILL #2 FACT SHEET ................................................................................65 ANNEX 4: CONTRACT BETWEEN TERRAPASS AND DEWITT ENERGY....................................66 ANNEX 5: BASELINE METHANE CAPTURE..........................................................................................67 ANNEX 6: ANALYSIS OF COMMON PRACTICE...................................................................................69



1 Description of Project

1.1 Project title

Clinton Landfill #2 Gas Collection and Combustion Project (hereafter, “Project”).

1.2 Type/Category of the project

• Project category which is part of a GHG program that has been approved by the VCS Board.

• Specify here if the project is a Grouped project. The proposed project activity falls into Sectoral Scope 13 – Waste Handling and Disposal under the Clean Development Mechanism (CDM). The project meets the criteria of a landfill gas project activity as defined in the CDM Approved Consolidated Baseline Methodology ACM0001 Version 10, “Consolidated baseline and monitoring methodology for landfill gas project activities.” The activity is an individual project, not a Grouped project.

1.3 Estimated amount of emission reductions over the crediting period including project size:

• Micro project: Less than 5,000 tonnes CO2 equivalent emissions reductions per year.

• Mega project: More than 1,000,000 tonnes CO2 equivalent emissions reductions per year

The Project is neither a Micro project nor a Mega project. The estimated emission reductions of the project activity are as noted in the chart below.

Calendar year Metric tons CO2e 2009 118,480 2010 114,929 2011 112,235 2012 115,661 2013 117,880 2014 109,279 2015 101,520 2016 94,497 2017 88,118 2018 82,306

Total reductions 1,054,904 Total years 10

Average per year 105,490



1.4 A brief description of the project:

The project activity is the capture and destruction of methane from the Clinton Landfill #2, via combustion engines. The generated electricity is sold to the local grid. However, the displacement of fossil fuels resulting from this activity is not included in this Project and emission reductions from the offsite use of electricity are not addressed in this Project Description (PD). The project includes an active landfill gas collection system including wells, piping, blowers, meters and valves; a back-up open flare; two 1.6-MW Caterpillar 3520C engine generator sets; gas conditioning equipment; a building to house the generators; and associated interconnection and metering devices. Note that the gas collection system and open flare were in place prior to the start of the Project. This PD seeks credit for voluntary emissions reductions over and above those achieved by the gas collection system in the baseline scenario.

1.5 Project location including geographic and physical information allowing the unique identification and delineation of the specific extent of the project:

Include GPS project boundaries. The Clinton Landfill is located at 9560 Heritage Road in Clinton, Illinois 61727, in DeWitt County, about 25 miles south of Bloomington, IL. The landfill occupies approximately 64 acres of a 153-acre permitted site. The Project is conducted within the property owned by Clinton Landfill, Inc. This property’s GPS coordinates are 40° 6’ 51.411” N and -88° 57’ 28.7994” W. The engines are housed in free-standing building along the northern edge of the waste area.

Location of state if Illinois within United States



Location of DeWitt County within the state of Illinois

Location of project relative to neighboring towns



1.6 Duration of the project activity/crediting period:

• Project start date: Date on which a financial commitment was made to the project and the project reached financial closure.

• Crediting period start date: the date the first monitoring period commenced

• VCS project crediting period: A maximum of ten years which may be renewed at most two times

In February 2004, DeWitt Energy Associates, LLC signed a contract with Clinton Landfill, Inc. for rights to develop an energy project using the landfill gas. The project achieved financial closure on December 30, 2005, when DeWitt Energy accepted financing from a local bank. Engines were delivered in April 2006. The project achieved commercial operation in January 2007. For financial planning purposes, the Project developer analyzed the project over a period of ten years, although the actual operational lifetime of the project will likely be determined by the lifetime of the engines. It is reasonable to assume that with proper maintenance, the engines will operate for approximately 20 years. The project start date is January 24, 2007. Prior to the project start, the landfill had approximately 4 million metric tons of waste in place. VCS 2007.1 states, “For non-AFOLU projects, VCS 2007.1 validation shall be completed within two years of the Project Start Date, or shall be completed or contracted before 19 November 2008. In relation to validation contracts entered into before 19 November 2008, validation shall be completed by 19 November 2009 and proof of contracting prior to 19 November 2008 shall be provided.” This project meets the requirement regarding validation contract, as the original contract for validation was established on October 31, 2008. The requested crediting period start date is July 1, 2009. Although commercial operation began on January 24, 2007, the landfill did not implement monitoring procedures compliant with the VCS requirements at that time. As a consequence, we are requesting a crediting start date that coincides with implementation of the compliant monitoring plan. As this PD is the initial VCS validation, we request a crediting period under VCS of 10 years.

1.7 Conditions prior to project initiation:

Clinton Landfill #2 is a small landfill located in Clinton, IL and operated by Clinton Landfill, Inc., a separately incorporated affiliate of Peoria Disposal Company, Inc. Clinton Landfill accepts municipal solid waste and non-hazardous special waste, which includes commercial solid waste, sludge, conditionally exempt small quantity generator waste, and industrial solid waste, among other waste types. Originally permitted in 1989, the Clinton Landfill receives approximately 867,000 cubic yards (262,000 short tons) of



waste per year, and is due to reach capacity in 2009.1 The landfill is permitted to accept 4.7 million cubic yards of waste. Ten waste cells are currently constructed. Of the ten cells, five are closed, with final cover in place. The remaining five continue to accept waste. The landfill includes 7 leachate monitoring stations and 15 groundwater monitoring wells. In 1998, an active methane recovery and destruction system was constructed at Clinton Landfill to maintain compliance with federal and state standards regarding the control of nonmethane organic compounds (NMOCs) and landfill gas (35 IAC, Part 220). The system includes 50 gas extraction wells. 40 of these wells precede the development of the gas-to-energy project; 10 were installed in October 2008. 18 additional wells will be built after waste reaches final grade in 2009.

1.8 A description of how the project will achieve GHG emission reductions and/or removal enhancements:

The Project represents a voluntary expansion of the existing gas management system. The original landfill gas management system collected gas and destroyed it in an open flare with a flow capacity of 550 scfm, using a 10-horsepower blower to maintain suction on the well field. The system was sufficient to maintain compliance with state and federal regulations. With the expansion of the system for electricity generation, the combustion equipment draws an average of 1,100 – 1,200 scfm, enough to power two 1.6MW generators. The additional gas collection and increase in combustion efficiency over and above the compliance system represents the destruction of methane that otherwise would have been vented directly to the atmosphere.

1.9 Project technologies, products, services and the expected level of activity:

The Project includes the following components:

• installation of a landfill gas conditioning skid; • installation of a more powerful blower to create a pull on the landfill gas; • installation of two engine-generator sets; • installation of meters and recorders to monitor project activity; • construction of a building to enclose the generator sets;

1 Basic information about the landfill, including permit number and owner information, can be found in

Annex 3, an excerpt from the Illinois EPA’s “Twenty-First Annual Landfill Capacity Report – 2007,” available online at http://www.epa.state.il.us/land/landfill-capacity/2007/



• staffing a landfill gas operations position to monitor and maintain the electrical generation equipment and gas collection system;

• and appropriate maintenance on all Project equipment. The well field and flare were in place prior to the development of the Project. Major new components are detailed below: Blower. By replacing the existing 10-horsepower blower with a significantly more powerful 75-horsepower version, the Project has achieved higher landfill gas collection efficiency. Generators. Two Caterpillar 3520C engines were installed for the Project. Each is capable of producing 1.6 MW of electricity at full load and requires about 550 scfm of landfill gas (depending on the methane concentration). Meters and Recorders. Monitoring and record equipment will be upgraded in the first half of 2009. A Rosemount Model 3095 Multivariable Mass Flow Transmitter is already in place at the generators, although it is not presently being used by the Project operator to capture gas flow data. Either the Rosemount or a comparable piece of equipment like the thermal mass flow meters from Sage Metering will be used to measure gas flow data. A handheld gas constituent analyzer, such as a Landtec GEM-2000 or Elkins Earthworks Envision, will be used to capture methane concentration data. Electricity generation is monitored by two separate meters, one of which shows gross production, and another that shows net contribution to the grid after parasitic load is subtracted out. All data will be logged electronically and consolidated weekly and monthly. Monitored data values will include nitrogen, methane, carbon dioxide and oxygen concentrations; gas flow, temperature, and pressure; kWh production and equipment uptime. Building. The building housing the generator sets is a Morton pole barn, a metal-clad structure with a poured concrete floor measuring 42 by 75 feet. Operations and Maintenance. DeWitt Energy operates and maintains the Project. O&M requires one full-time manager to run the plant, as well as a half-time technician. Several other technicians fill in on a part-time, as-needed basis.

1.10 Compliance with relevant local laws and regulations related to the project:

The VCS PD shall include identification of relevant local laws and regulations related to the project and demonstration of compliance with them.

The landfill operates under Permit No. 0398080007 granted by the Illinois Environmental Protection Agency (IEPA). In addition, the landfill must obtain operating permits from the IEPA land, air, and water bureaus. The current Bureau of Land permit is No. 1996-



102-LF, issued subject to the development, operating, and reporting requirements for non-hazardous waste landfills in Title 35 Illinois Administrative Code (35 IAC), Subtitle G: Land Pollution (Regulations), Parts 810, 811, 812, 813, and 814. The current Bureau of Air permit is No. 99110013, which ensures compliance under the Title V Clean Air Act Permit Program. The current Bureau of Water permit is No. IRL000312. In addition, the Project requires individual permits:

• The Dept. of Planning and Development for town of Texas, DeWitt County issued a building and construction permit No. 5399 on February 23, 2005.

• The IEPA Dept. of Air issued permit No. 039808AAE on May 18, 2005 for operation of the generators, pursuant to 40 CFR 52.21 (b)6; 35 IAC 203.112 and 203.136; Illinois Administration code 2116130; and Sec. 39.5(1) of Illinois Environmental Protection Act. This permit covers one year of engine emissions, starting from the Project online date.

• In September, 2007 the Project submitted application No. 05-745-20 for a longer-term air permit under the Clean Air Act. Because the board is three years behind on permit approvals, the application acts as an interim permit until approval is granted.

• On January 10, 2007, The Federal Energy Regulatory Commission granted permit No. QF-07-64-000 under Federal Energy Regulatory Act 556: self-certification of qualifying facility status for a proposed small power generation facility.

Copies of all Project permits will be made available at the validation site visit. A Freedom of Information Act request to the state of Illinois turned up no evidence of Project or landfill non-compliance with applicable regulatory statutes, outside of minor temporary exceedences typical of such operations, which are discussed further in section 2.4.

1.11 Identification of risks that may substantially affect the project’s GHG emission reductions or removal enhancements:

The following risks could substantially reduce the project’s emission reductions:

• The Project owners could have improper record keeping, or suffer a catastrophic data loss that would make it difficult to document reductions.

• The Project owners could suffer problems with calibration or functioning of meters in the Project and face difficulties documenting reductions.

• The Project management may change and the new operators may neglect the system.

• The flaring or generation components may fail or underperform (e.g. require more maintenance than expected) over several months, allowing methane emission to escape the collection system into the atmosphere.



1.12 Demonstration to confirm that the project was not implemented to create GHG emissions primarily for the purpose of its subsequent removal or destruction.

The Project collects and combusts methane from an existing source (the landfill). None of the Project components create methane. Therefore the project’s initiation does not result in an increase in greenhouse gas emissions relative to the baseline scenario.

1.13 Demonstration that the project has not created another form of environmental credit (for example renewable energy certificates).

If the project has created another form of environmental credit, the proponent must provide a letter from the program operator that the credit has not been used and has been cancelled from the relevant program.

The reductions presented in this PD do not create another form of environmental credit. However, at the Project facility, renewable energy generation produces renewable energy certificates (RECs). The RECs are purchased by Ameren, the alternative retail energy supplier that also purchases the generated electricity. Guidance from the VCS secretariat makes it clear that the project boundary can be drawn such that the methane destruction credits are separated from the indirect reductions from grid power sales: 2

The VCS treats these projects the same way as the CDM. Both the reductions from the methane destruction and renewable energy electricity generation can create VCUs as long as the project passes the VCS additionality test. Or the electricity generation can create RECs and the methane combustion can create VCUs.

Based on the above, the project boundary has been drawn to exclude the exported electricity. The Project does not make use of the renewable electricity onsite, except for the parasitic use by the Project itself; therefore our calculations assume the amount of electricity generated utilizing the landfill gas collected in the Project activity is zero.

1.14 Project rejected under other GHG programs:

Projects rejected by other GHG programs, due to procedural or eligibility requirements where the GHG program applied have

2 Personal correspondence with acting VCS Program Manager. Feb 5, 2008.



been approved by the VCS Board; can be considered for VCU but project proponents for such a project shall:

• clearly state in its VCS PD all GHG programs for which

the project has applied for credits and why the project was rejected, such information shall not be deemed commercially sensitive information; and

• provide the VCS verifier and Registry with the actual rejection document(s) including explanation; and

• have the project validated against VCS program requirements.

This Project has not been rejected under other GHG programs.

1.15 Project participants / roles and responsibilities, including contact information of the project proponent, other project participants:

Project proponent TerraPass, Inc. Adam Stein, Senior Project Manager, Carbon Management Services, [email protected] TerraPass is responsible for creating the PD, managing the validation and verification of the credits, and representing them for sale. Project owner DeWitt Energy Associates, LLC Edwin Ingalls, General Manager, [email protected] DeWitt Energy Associates owns and operates the plant that generates electricity from the captured landfill gas. DeWitt Energy is also the original owner of the carbon credits that will be offered for sale. Landfill owner Clinton Landfill, Inc. (217) 935-8028 Clinton Landfill, Inc. is a private landfill operator that owns and operates the well field and gas collection system at the Clinton Landfill. They sell the collected gas along with environmental attributes to DeWitt Energy, and have no direct involvement in the operation or ownership of the Project, other than to deliver the gas to the Project site.

1.16 Any information relevant for the eligibility of the project and quantification of emission reductions or removal enhancements, including legislative,



technical, economic, sectoral, social, environmental, geographic, site-specific and temporal information.):

All relevant information is captured in other sections of this PD.

1.17 List of commercially sensitive information (if applicable):

Any commercially sensitive information that has been excluded from the public version of the VCS PD that will be displayed on the VCS Project Database shall be listed by the project proponent.

The following information is proprietary and confidential:

• Detailed spreadsheet models relevant to ACM0001, developed by TerraPass; • Financial additionality spreadsheets including screenshots and backup data and

any discussion of the actual or pro forma payments or costs to DeWitt Energy Associates;

• Contract between DeWitt Energy Associates and TerraPass.



2 VCS Methodology

2.1 Title and reference of the VCS methodology applied to the project activity and explanation of methodology choices:

Projects shall use one of the VCS program approved project methodologies and provide information relevant to methodology deviations or methodology revisions.

The approved methodology applied for this project is the CDM Approved Consolidated Baseline Methodology ACM0001 Version 10, “Consolidated baseline and monitoring methodology for landfill gas project activities.” The following tools are referenced in the Methodology, and are also applied:

• “Tool to determine project emissions from flaring gases containing methane (EB28, annex 13)”

• “Tool to calculate baseline, project and/or leakage emissions from electricity consumption (version 01) (EB39, annex 7)”

• “Tool for the demonstration and assessment of additionality (version 5.2) (EB39, annex 10)”

• “Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site (version 04) (EB41, annex 10).”

• “Tool to calculate the emission factor for an electricity system (Version 1.1) (EB35, Annex 12).”

2.2 Justification of the choice of the methodology and why it is applicable to the project activity:

ACM0001’s applicability is articulated in the methodology as follows:

This methodology is applicable to landfill gas capture project activities, where the baseline scenario is the partial or total atmospheric release of the gas and the project activities include situations such as:

a) The captured gas is flared; and/or b) The captured gas is used to produce energy (e.g.

electricity/thermal energy); c) The captured gas is used to supply consumers through

natural gas distribution network. If emissions reductions are claimed for displacing natural gas, project activities may use approved methodology AM0053.

This project involves scenarios (a) and (b).



2.3 Identifying GHG sources, sinks and reservoirs for the baseline scenario and for the project:

The following figure describes the Project boundary: The following table describes the sources of emissions from the project: Source Gas Included? Justification / Explanation

CH4 Yes The major source of emissions in the baseline. N2O No N2O emissions are small compared to CH4 emissions

from landfills. Exclusion of this gas is conservative.

Emissions from decomposition of waste at the landfill site CO2 No CO2 emissions from the decomposition of organic

waste are not accounted for. CO2 No Emissions are considered biogenic. CH4 Yes Emissions due to destruction inefficiencies are

included.

Base

line

Emissions from flaring in the baseline scenario

N2O No Excluded for simplification. This is conservative.

Methane not destroyed

Biogenic CO2 from combustion

Biogenic CO2 from landfill gas

Generators Open flare Electricity sold to grid

Landfill Landfill methane emissions

Landfill gas capture system

CO2 from project power use



Source Gas Included? Justification / Explanation CO2 No Fossil fuel consumption by the flare is part of the

baseline scenario. CH4 No Excluded for simplification. This emission source is

assumed to be very small.

Onsite fossil fuel consumption due to the flare

N2O No Excluded for simplification. This emission source is assumed to be very small.

CO2 Yes May be an important emission source. CH4 No Excluded for simplification. This emission source is

assumed to be very small.

Electricity consumption by the project landfill gas recovery systems N2O No Excluded for simplification. This emission source is

assumed to be very small. CO2 No Emissions are considered biogenic. CH4 Yes Emissions due to destruction inefficiencies are

included.

Proj

ect A

ctiv

ity

Emissions from flaring of methane and from combustion in electricity generators

N2O No Excluded for simplification. This emission source is assumed to be very small.

2.4 Description of how the baseline scenario is identified and description of the identified baseline scenario:

The project proponent shall select the most reasonable baseline scenario for the project. This shall reflect what most likely would have occurred in the absence of the project.

In this section we apply the steps to identify the baseline scenario under ACM0001. The methodology determines the baseline scenario through the following steps:

1. Define alternative scenarios to the proposed CDM project activity. 2. Identify the fuel for the baseline choice of energy source taking into account

the national and/or sectoral policies as applicable. 3. Barriers and/or financial assessment of alternatives. 4. Select credible and plausible alternative scenario that results in the lowest

baseline emissions. Step 1: Identification of alternative scenarios

Identification of alternatives must follow Step 1 of the “Tool for the Demonstration and Assessment of Additionality.” This step is called, “Identification of alternatives to the project activity consistent with current laws and regulations.” Sub-Step 1a: Define alternatives to the project activity

The additionality tool provides the following guidance for landfill gas projects:

In the case of a landfill gas capture project, the service provided by the project includes operation of a landfill. Alternatives scenarios to the project could include different



ways to operate the landfill, such as no capture of methane, capture and flaring of the methane or capture and combustion of the methane for energy generation.

The tool also requires examination of continuation of the existing situation, and the possibility of the Project continuing without registering under a voluntary market standard such as VCS2007 (the VCS language here is substituted for the CDM regulatory language included in the tool). The following alternatives to the Project have been identified:

1. Continuation of the pre-project situation: operation of the existing landfill gas collection system and flare to maintain compliance with 35 IAC, Part 220 (Nonmethane Organic Compounds). This alternative is equivalent to scenario LFG2 in ACM0001.

2. Execution of the Project without registration under a voluntary carbon standard such as VCS 2007. This alternative is equivalent to scenario LFG1 in ACM0001.

The following alternatives have been rejected and won’t be considered further:

1. Operation of the landfill with no capture of methane. This alternative would violate federal NSPS guidelines.

2. Voluntary expansion of the pre-existing flaring system. The landfill is under no regulatory compulsion to expand the system and faces a financial disincentive to making the system larger than necessary (see the discussion of Project baseline for more details).

3. Alternative end uses for the landfill gas. Other less common uses of landfill gas include pipeline injection and direct use as a source of thermal energy. The size and geographic location of the landfill make the finances of such alternative end uses unworkable. For example, the landfill investigated whether gas could be piped to a nearby school for use as heating fuel, and found capital costs to be more than triple the level required to justify investment.3

Scenario 1 – Continuation of pre-project situation Prior to the Project’s commencement, a landfill gas collection and combustion system was in place. The system was put in place in 1998 to comply with federal and state requirements for the control of nonmethane organic compounds (NMOCs), as described in 35 IAC, Section 220. The gas collection and control system consists of 50 wellheads connected via a header pipe to an open flare with a capacity of 550 scfm. Monitoring records show that in the year prior to the online date of the Project, the gas collection system captured approximately 2.6m scf of landfill gas at standard temperature and pressure (68° F and 1 atmosphere) at an average methane concentration of 59.8%. This gas volume equates to 3,899 metric tons of methane.

3 http://pantagraph.com/articles/2008/10/31/news/doc490a50c182baf736604969.txt



This scenario – continued use of the site as an active landfill with the existing collection and control system in place – is a realistic and credible alternative. Scenario 2 – Execution of the Project without registration under a voluntary carbon standard This scenario requires DeWitt Energy, or some similar party, to invest in the enhanced recovery of landfill gas without realizing return from carbon credits. To be credible, this investment would need to be justified on economic grounds. The economic motivations will be discussed further in the analysis of finances and barriers. Sub-Step 1b: Consistency with Mandatory Laws and Regulations

This step requires analysis of each alternative’s compliance with applicable laws and regulations, and elimination of alternatives that are not in compliance. Scenario 1: continuation of pre-project situation The pre-project gas collection and combustion system was constructed to maintain compliance with air regulations under the U.S. Clean Air Act. The U.S. Clean Air Act establishes thresholds which require the installation of an active landfill gas collection system, specifically the Emission Guidelines and Standards of Performance for MSW Landfills (EG & NSPS), 40 CFR Part 60, Subparts Cc and WWW, published March 12, 1996, and amended June 16, 1998, February 24, 1999, and April 10, 2000. These regulations have been adopted in total by the State of Illinois (35 IAC, Part 220). Further, 35 IAC lays out a series of performance metrics and monitoring criteria to establish whether the system in place is adequate to control NMOC emissions and surface and subsurface methane:

1. Gas extraction rate a. Requirement: the gas collection system must have an extraction rate

“sufficient to maintain a negative pressure at all wellheads in the collection system without causing air infiltration, including any wellheads connected to the system as a result of expansion or excess surface emissions, for the life of the blower.” (35 IAC 220.110)

b. Test method 1: “For the purpose of demonstrating whether the gas collection system flow rate of an active collection system is sufficient, the owner or operator shall measure gauge pressure in the gas collection header at each individual well monthly.” (35 IAC 220.240 (a) (3))

c. Test method 2: “For purposes of identifying whether excess air infiltration into the landfill is occurring, the owner or operator shall monitor each well on a monthly basis for temperature and nitrogen or oxygen” (35 IAC 220.240 (a) (5))



d. Corrective action: “If negative pressure cannot be achieved without excess air infiltration within 15 calendar days after the first measurement, the gas collection system shall be expanded to correct the exceedence within 120 days after the initial measurement of positive pressure.” (35 IAC 220.240 (a) (3))

2. Maximum flow capacity a. Requirement: “the landfill gas shall be conveyed to a gas control system

through the collection header pipe(s). The gas mover equipment shall be sized to handle the maximum gas generation flow rate expected for the period of intended use” (35 IAC 220.220(b)(3))

b. Test method: “calculations made using the equations in subsection (a)(1)(A) or (a)(1)(B) of this Section or other methods shall be used to predict the maximum gas generation rate over the intended period of use of the gas control system equipment” (35 IAC 220.240 (a) (1)(C))

c. Corrective action: not applicable. System design must be approved when the system is permitted.

3. Control of surface and subsurface methane a. Requirement: “active collection wells, horizontal collectors, surface

collectors, or other extraction devices shall be sited at a sufficient density throughout all gas producing areas” (35 IAC 220.220(b)(1))

b. Test method: “After installation of the collection system, the owner or operator shall monitor surface concentrations of methane along the entire perimeter of the collection area and along a pattern that traverses the landfill at 30-meter intervals (or site-specific established spacing) for each collection area on a quarterly basis using an organic vapor analyzer, flame ionization detector, or other portable monitor” (35 IAC 220.240(c)(1))

c. Corrective action: “For any location where there are three monitored exceedences within a quarterly period, a new well or other collection device shall be installed within 120 calendar days after the initial exceedence. An alternate remedy to the exceedence, such as upgrading the blower, header pipes, or control device, and a corresponding timeline for installation may be submitted to the Agency for approval.” (220.240(c) (4) (E))

These performance metrics bear on the question of whether the continuation of the pre-project scenario would satisfy all applicable regulatory requirements. The landfill files an annual report detailing its monitoring plan, any exceedences, and planned enhancements to the system in the coming year. From the most recent report, dated April 25, 2008:4

4 Solid Waste Landfill Groundwater, Leachate, Facility and Gas Reporting Form, filed for the Clinton

Landfill on April 25, 2008. Obtained by TerraPass from IEPA via Freedom of Information Act request.



The gas monitoring program at the facility consists of a series of perimeter gas monitoring devices (GMD) outside the waste boundary, three continuous air monitoring devices (CAMD), and three ambient air monitoring (AAM) locations monitoring for potential landfill gas migrations. A series of interior gas extraction wells (IG) installed within the waste boundary to collect landfill gas are also part of the monitoring system. CLI has installed and operates an active landfill gas extraction and control system. In accordance with Special Condition X.6 of the facility permit, the interior gas monitoring devices, and ambient air quality locations are monitored at least annually. However, CLI monitors landfill gas at these locations on a monthly basis. The perimeter gas monitoring devices are monitored at least quarterly in accordance with Special Condition X.11 of the facility permit.

Monitored parameters include pressure, methane, oxygen, nitrogen, and carbon dioxide. We use these reports to determine whether the existing gas control system was sufficient to maintain regulatory compliance. Gas extraction rate: project monitoring indicates that the system has performed well as designed. Exceedences for oxygen and nitrogen infiltration occurred sporadically in 2003 and 2004, and then dropped significantly in 2005 and following years. Pressure exceedences are rare throughout all monitoring periods. The drop in air infiltration exceedences doesn’t correspond to any expansions or major modifications to the gas control system. (Five new collection wells became active in early 2006, and several more were installed at the end of 2008, but neither expansion corresponds to any observed exceedences.) Air infiltration exceedences are often caused by construction or other activity at the landfill. For example, as more of the landfill reaches final grade, construction activity declines, and gas collection pipes that had been laid across the surface of the waste mass are buried. Such sporadic exceedences are typical, and do not appear to have prompted any remedial action. Maximum flow rate: regulations require that a landfill gas collection system be sized to handle maximum expected gas flow. The fact that the existing system was approved by the IEPA is an indication that the design is adequate to handle maximum projected gas flow. Further, gas flow is usually projected using a first-order decay model such as the EPA LandGEM model or the equations in the CDM “Tool to determine methane emissions avoided from disposal of waste at a solid waste disposal site.” The former indicates a peak gas flow in 2012, three years after project closure. A model developed by TerraPass based on the CDM equations shows a peak even sooner, in 2009. Given the near-term projected peak, it is unlikely that the landfill will encounter higher-than-expected gas flow in the future. Control of surface and subsurface methane: project monitoring indicates that the system has performed well as designed. As noted in the annual reports filed for years 2003



through 2007 (the most recent available), specific wells have registered occasional exceedences for methane in every year. Such sporadic exceedences are typical, and do not appear to have prompted any remedial action. For example, the 2006 report notes “some wells exceeding 50% of the LEL” for methane, and then states, “No changes to the gas monitoring program are anticipated for calendar year 2007 at the time of this report.”5 Based on the near-term closure date of the landfill and the lack of exceedences sufficient to prompt remedial action in any of the annual monitoring reports delivered to the IEPA during the period preceding and concurrent with the Project activity, we conclude that Scenario 1 is compliant with applicable regulations. We note, however, that the number of gas collection wells has expanded over time as the landfill has accepted more waste and more portions of the landfill have reached final grade. Five wells were installed in 2006, 10 additional wells were installed in 2008, and 18 more wells will be installed when the landfill closes in 2009. This expansion of the system is expected, and will be accounted for in the emissions baseline. Scenario 2: Execution of the Project without registration under a voluntary carbon standard From a regulatory standpoint, Scenario 2 is similar to Scenario 1, except that an engine is used to destroy the collected landfill gas, rather than a flare. In 35 IAC, “enclosed combustors” are listed as an acceptable means of destroying landfill gas. “Examples include, but are not limited to, an enclosed flare, a boiler, and an internal combustion engine” (35 IAC 220.110). Therefore, Scenario 2 is also compliant with applicable regulations. The Project uses two engines to combust landfill gas. In the event that one engine should need to be shut down for maintenance or repair, the other engine will continue to destroy landfill gas, ensuring compliance with applicable laws. In the unusual event that both engines need to be shut down, gas can be allowed to build up in the waste mass for short periods of time with no problematic effect. Should both engines need to be taken offline for longer amounts of time, then the back-up flare will be connected to the gas collection system and used to destroy landfill gas, ensuring regulatory compliance. Step 2: Identify the fuel for the baseline choice of energy

source taking into account the national and/or sectoral policies as applicable.

5 Solid Waste Landfill Groundwater, Leachate, Facility and Gas Reporting Form, filed for the Clinton

Landfill on April 25, 2007. Obtained by TerraPass from IEPA via Freedom of Information Act request.



Demonstrate that the identified baseline fuel is available in abundance in the host country and there is no supply constraint.

This requirement pertains to credits associated with energy or thermal aspects of landfill projects. Since this Project does not include credits for electricity generation or thermal energy use, this section is not applicable. Step 3: Assess which of these alternatives should be excluded

from further consideration due to barriers or because they are economically unattractive (Additionality tool steps 2 and/or 3)

Additionality Tool, Step 2: Investment Analysis

Determine whether the proposed project activity is economically or financially less attractive than at least one other alternative, without the sale of carbon credits.

Additionality Tool, Sub-Step 2a: Determine appropriate analysis method

If the Project has no source of income other than the carbon credits, then a simple cost analysis (Option I) may be used. However, the Project generates income streams from electricity sales, renewable energy credits, and investment tax credits, in addition to carbon credits. Therefore, Option II, investment comparison, or Option III, benchmark analysis, must be used. We choose Option III, benchmark analysis. Additionality Tool, Sub-Step 2b – Option III: Apply Benchmark Analysis

We will calculate the equity internal rate of return (IRR) compared to a benchmark value for Scenario 2, the Project without carbon revenue. Since Scenario 1 is a continuation of the existing situation and requires no investment, we can assume Scenario 1 will occur unless Scenario 2 provides a sufficient IRR to attract private investment. The data for all calculations in this section reflect the Project developers’ view of the Project finances prior to the financial closure date. Financial closure occurred when the project developer accepted financing on December 30, 2005. Because financing was contingent on the arrangement of a power purchase agreement, some of the payment figures were known with certainty in advance. Others, including operational metrics such as engine uptime and maintenance, are pro forma values based on the Project developer’s reasonable planning assumptions. To apply the benchmark analysis, we must provide a recognized benchmark indicator for comparison. We choose a benchmark rate of 15%, a conservative value based on expected returns for projects of a similar type. For example, according to the U.S. EPA’s



Handbook on financing similar types of environmental projects (methane recovery projects at farms):6

…banks or other lenders currently prefer to see a Rate of Return between 12% and 18% for most types of projects. Outside investors will typically expect a ROR of 15% to 20% or more.

The U.S. EPA’s “Landfill Gas-To-Energy Project Development Handbook” notes:7

The ROR on equity and the NPV of owner's cash flows are two measures of the financial returns to the project owner. The owner's rate of return on equity ranges from approximately 12% to 18% for most types of power projects.

Although guidance from the CDM executive board indicates that industry benchmarks for rates of returns are preferred over the hurdle rates used by individual investors, it is worth noting that the project developer used a return on equity of 15% in its pro forma project planning. The project developer regards a 15% hurdle rate as a floor, and prefers a return of 17% or higher. Additionality Tool, Sub-Step 2c – Calculation and comparison of

financial indicators

Assumptions We use 10 years as our base analysis, which represents a typical planning horizon for an investment project. We also test this assumption in the sensitivity analysis by expanding the analysis to a 15-year horizon. The value of electricity sold is 3.5 cents per kWh during the first three years of operation, and then steadily escalates to 4.0 cents per kWh in 2016. This value was known in advance of financial closure, and will not be subjected to sensitivity analysis. At the time of financial closure, Project developers considered both renewable energy credits (RECs) and carbon offsets as a source of revenue. The power purchase with Ameren, signed prior to financial closure, specifically references “renewable/energy credits or other like benefits or attributes (‘Credits’).” Developers were aware of both pending renewable portfolio standard legislation in the state of Illinois and pending greenhouse gas legislation at the federal level. Since RECs are part of the climate change mitigation marketplace in the U.S. just as carbon offsets are, REC income must be subtracted in the “no carbon revenue” scenario. The value of the RECs is variable based

6 AgStar Handbook, Second Edition, June 30, 2004. Chapter 7, page 7-1. Available at

http://epa.gov/agstar/pdf/handbook/chapter7.pdf 7 Landfill Gas-to-Energy Project Development Handbook, 1996, Chapter 5, page 5-22. Available at

http://www.epa.gov/lmop/res/pdf/handbook.pdf



on market rates, but the pro forma assumption was a REC value of 0.5 cents per kWh. The treatment of RECs as carbon revenue will be subjected to sensitivity analysis. We assume all generators operate at 90% capacity as soon as they come online (10% maintenance and downtime), and each generator has a parasitic load of 100kw, consistent with project planning assumptions. This assumption results in all project gas being used to generate electricity, again, a conservative additionality assumption. We assume payment for investment tax credits based on the actual sales arrangement at the time of financial closure. The Project developers were to be paid $0.385/MWh for the first three years of the project and $0.30/MWh for the next seven years. No investment tax credits are available after ten years. Finally, we assume a gas license payment based on the actual purchase agreement between the Project developers and the landfill operator at the time of financial closure. The gas license payment varies from year to year, starting at $9.79 per engine operating hour in 2007, rising to $10.25 per engine operating hour in 2008 and 2009, and then descending to $6.55 per engine operating hour in 2018, at which point the payments remain flat. Pro forma O&M costs are estimated to be 1.5 cents per kWh, escalating by 2% per year. Finally, the end-of-life value of the equipment is assumed to be $1.3 million in 2007, declining by $100,000 per year. Clean up costs are estimated at $100,000. The project developer is contractually obligated to clean up the Project site and dispose of the engines at end-of-life. These obligations are estimated to be $100,000. Figures are based on estimates provided by the project developer. Financing for the project includes $2,700,000 loan at 9.5% interest. To estimate tax payments, we assume a ten-year straight-line depreciation of the project’s capital assets. This is a conservative assumption, as it eliminates tax payments in the first ten years. Scenario 1: Continuation of the current situation Since the current activities – destruction of landfill gas using existing collection system and open flare – do not require incremental investment, no return on equity is necessary or appropriate, and we can assume that these activities would continue absent the investment described in Scenario 2. Scenario 2: Project scenario The cash flows to the Project absent REC revenue or carbon revenue are as follows (all dollar figures in thousands):



2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Revenue

Loan 2,700 Electricity 828 828 828 828 828 840 864 888 911 947

ITC 9 9 9 9 7 7 7 7 7 7 Resale - - - - - - - - - 400

Expenses

CAPEX 3,487 Gas 154 162 162 143 143 143 143 143 143 148

O&M 355 362 369 377 384 392 400 408 416 424 Taxes - - - - - - - - - -

Interest 370 370 370 370 370 370 370 370 370 370 Clean up - - - - - - - - - 100

FCF (829) (57) (64) (52) (62) (58) (42) (26) (11) 311

IRR -16.8% Because the equity IRR is less than the required 15%, this scenario is an unattractive investment and would not proceed. Additionality Tool, Sub-Step 2d: Sensitivity Analysis

1. Including REC sales at 0.5 cents/kWh Equity IRR: 5.5%

2. Increasing investment time horizon from 10 to 15 years

Equity IRR without RECs: -5.0% Equity IRR with RECs: 10.4%

3. Including carbon revenue at $5.00/metric ton CO2

Equity IRR without RECs: 23.3% Equity IRR with RECs: 53.4%

The sensitivity analysis reveals that the potential rate of return to equity varies greatly with modifications in the inputs assumptions. In part, this reflects the highly leveraged nature of the project. Regardless, only the scenarios involving carbon offset revenue clear the hurdle rate of 15%.



Although additionality analysis focuses on the financial expectations at the time of financial closure, it is worth noting that in actual practice, several project planning assumptions have proved overly optimistic, and the Project is presently losing money:

1. Equipment uptime has been lower than expected. 2. O&M costs have been significantly higher than expected (roughly $0.02/kWh). 3. Because the Project missed a contractual deadline, investment tax credit payments

have been lower than in the pro forma financial statements. In the “Tool for the demonstration and assessment of additionality,” The CDM Executive Board provides the following guidance: “Input values used in all investment analysis should be valid and applicable at the time of the investment decision taken by the project participant.” Therefore, actual project performance doesn’t bear directly on the additionality determination. However, the poor real-world performance of the project reinforces two relevant points:

1. The low equity IRRs projected in our calculations in the absence of carbon offset revenue do accord with reality. Our calculations show an economically marginal project, and in actual fact small fluctuations in project performance have prevented the project from achieving break-even returns.

2. Although the sensitivity analysis helps to show whether under different conditions the project would be economically attractive, actual project performance serves as a reminder that pro forma financials also include significant downside risk. The project was highly risky at the time of financial closure, and the 15% benchmark rate is therefore conservative.

When voluntary greenhouse gas market attributes are taken into account, the Project becomes attractive. Carbon revenue serves to insulate the project from downside risks, making the Project worthy of investment. Outcome of Additionality Tool Step 2:

The Project without the carbon market revenue is unlikely to be financially attractive to an investor when compared to benchmarks, as noted above. The addition of carbon revenues to the Project financials substantially improves the project’s expected returns and makes the Project financially attractive. Step 4: Where more than one credible and plausible alternative

remains, project participants shall, as a conservative assumption, use the alternative baseline scenario that results in the lowest baseline emissions.

Based on the investment analysis, the only credible alternative to the Project is Scenario 1, where gas collection activity continues as before the Project. This alternative is the same as ACM0001’s LFG2 scenario (“Atmospheric release of the landfill gas or partial capture of landfill gas and destruction to comply with regulations or contractual



requirements, or to address safety and odour concerns”). Therefore the methodology continues to be applicable. Since Scenario 1 is the only credible and realistic alternative to the Project, Scenario 1 is defined as the baseline scenario.

2.5 Description of how the emissions of GHG by source in baseline scenario are reduced below those that would have occurred in the absence of the project activity (assessment and demonstration of additionality):

The project proponent shall in the VCS PD, in addition to describing how the project meets the VCS methodology, demonstrate that the project is additional based on one of the tests, the project test, the performance test, and technology test.

We choose to use the VCS Project Test for this section. The Project Test involves three steps, each of which is applied below. Step 1: Regulatory Surplus The Project is required by the U.S. Clean Air Act to capture landfill gas. As noted in Section 2.4, the relevant statutes impose a variety of performance criteria on the gas collection and destruction system, all of which were being met by the system in place prior to the expansion of collection activity for the gas-to-energy project. Therefore, we seek credits for these surplus greenhouse gas destructions, which were not compelled by any relevant federal, state, or local regulation. Step 2: Implementation Barriers Please see section 2.4 for this discussion as it pertains to barriers to capital investment. In accordance with ACM0001 and the “Tool for the Assessment and Demonstration of Additionality,” this Project faces investment barriers in the form of an inadequate financial return compared to other alternatives, which carbon revenues help to overcome. Step 3: Common Practice test This is the same as Step 4 of the Additionality Tool. A full discussion follows. Additionality Tool, Sub-step 4a: Analyze other activities similar to

the proposed project activity:

The U.S. EPA’s Landfill Methane Outreach Program, updated in January 2009, ranks thousands of U.S. landfills by landfill gas project status. Existing projects are listed as operational or under construction (or shutdown, although we exclude these from analysis). Landfills deemed particularly promising for an end use project are listed as candidate sites. And other landfills are listed as “potential” sites for end use projects.



According to the database, only 25% of landfills considered “candidate” or “potential” sites for gas use projects actually have them.8 Although a significant minority of landfills in the U.S. are pursuing end use projects, such projects are not yet common practice in the industry. Below, we consider factors that affect whether an individual landfill decides to proceed with a project. Additionality Tool, Sub-Step 4b: Discuss any similar options that are

occurring:

As noted above, landfill gas-to-energy projects are not standard practice in the U.S. However, a growing number of projects are in operation. Typically, the key determinant of whether a project moves forward is whether it is likely to yield a favorable financial return. Although a host of factors affect the profitability of a project, ranging from prevailing electricity prices to the availability of carbon revenue, one of the most basic determinants is the size of the landfill. Holding other factors such as age and waste composition equal, larger landfills produce more gas, and are therefore more likely to generate enough revenue to overcome fixed project costs. Clinton Landfill is one of the smallest landfills to have a landfill gas-to-energy system. According to the LMOP database, there are 35 projects currently in operation in Illinois. The average amount of waste in place on landfills with operational projects is 8.2 million tons waste in place, more than double the 3.8 million tons waste in place at Clinton.9 Moreover, a qualitative analysis of the landfills of comparable size or smaller that also have end use projects reveals that most such projects have extenuating circumstances that facilitated their development. A full analysis is presented in Annex 6. Given the relative infrequency of landfill gas-to-energy projects generally in the U.S. and the small size of the Clinton Landfill relative to similar projects in the region, we feel that the Project does not represent common practice in the industry. Only projects that can be justified on financial grounds move forward, and, as demonstrated in the investment analysis, Clinton is not a favorable project in the absence of carbon revenue.

8 http://www.epa.gov/lmop/proj/index.htm 9 Note that waste-in-place figures vary a bit by source, and our model of landfill gas generation uses

slightly different figures based on historical waste acceptance records. These variations are not considered meaningful for this analysis.



3 Monitoring

3.1 Title and reference of the VCS methodology (which includes the monitoring requirements) applied to the project activity and explanation of methodology choices:

The monitoring methodology follows ACM0001.

3.2 Monitoring, including estimation, modeling, measurement or calculation approaches:

• Purpose of monitoring • Types of data and information to be reported, including

units of measurement • Origin of the data • Monitoring, including estimation, modeling, measurement

or calculation approaches • Monitoring times and periods, considering the needs of

intended users • Monitoring roles and responsibilities • Managing data quality

The purpose of monitoring is to ensure the Project accomplishes its greenhouse gas reductions as expected by DeWitt Energy, and to ensure its emission reductions are creditable pursuant to this PD and the Voluntary Carbon Standard. Although the project began in February 2007, historical monitoring has not been compliant with ACM0001. The forward-looking monitoring plan – including equipment, process implementation, recordkeeping, and calibration procedures – will go into effect in the first half of 2009, pending successful Project validation. Some elements of the new plan are already in place. For example, DeWitt Energy aggregates hourly data on a wide variety of operational parameters and tracks them via a web-based reporting tool. Likewise, a continuous gas flow monitor has been in place since project start (but used only by the landfill to monitor gas flow, not by the Project owner). The data to be reported are:

• Total landfill gas captured • Landfill gas flow to the generators • Landfill gas constituent concentration • Operating hours of the generators • Quantity of electricity generated • Quantity of grid electricity used by Project equipment • Quantity of waste disposed at the landfill



The origin, measurement techniques, monitoring time periods, responsibilities, and data quality management systems are described below. Presently, there are no plans to monitor gas flow to the back-up flare, because the flare isn’t physically connected to the collection system. 100% of the landfill gas is sent to the generators. To use the flare, landfill technicians have physically disconnect the flow to the generators and reconnect it to the flare, a procedure that would only be performed if both generators needed to be taken offline simultaneously for a significant period of time. The decision not to monitor flow to the flare is a conservative one, as it can only result in a reduction of the number of credits otherwise available. Landfill gas data

Landfill gas flow to the generator sets will be monitored on a continuous basis by a monitor located upstream of the generators, incorporated into the gas conditioning skid. Presently the landfill uses a Rosemount Model 3095 Multivariable Mass Flow Transmitter to collect this data, although another similar monitor such as the Sage Prime industrial mass flow meter may be used to record project gas flow. Data are automatically adjusted to standard temperature and pressure and saved locally to a memory card. Values are retrieved daily, and consolidated data is saved to a PC hard drive. Methane concentration will be measured one or more times per week via a handheld monitor such as the Landtec GEM-2000 or Elkins Earthworks Envision. All data will be recorded to a PC hard drive. Note that all landfill gas is directed to the generators, so the generator gas flow is equal to total gas flow. On occasions that both generators are simultaneously down for repair, gas is allowed to accumulate in the waste mass until generators are running again. If both generators should ever be taken offline for a significant period of time, gas would be directed to the back-up flare. In the roughly two years since the project began, the back-up flare has only been used once. Should the back-up flare ever be used, the destroyed methane won’t be eligible for carbon crediting. Responsibilities All landfill gas data is the responsibility of the DeWitt Energy staff. Quality control The continuous flow meter will be recalibrated by factory representatives on an annual basis. Records of these calibrations will be maintained at the site, and will be available for inspection. Records of field check and recorder flow rates will be maintained on-site. The handheld meter for methane concentration measurement will be field-calibrated prior to each day’s use following manufacturer’s recommended procedures, and the results of these calibrations documented and maintained on-site.



Generator data

• Quantity of electricity generated • Operating hours of the generators • Quantity of grid electricity used by Project equipment

Electricity output is tracked by two separate meters, one a gross meter that records total kilowatt-hours, and another that records net electricity delivered to the grid. These meters are owned and maintained by Ameren, the alternative retail energy supplier that purchases the generated electricity. The quantity of electricity generated by each engine set will be aggregated hourly and recorded using a web-based reporting tool. Each generator’s operational status can be derived from hourly records of electricity generated. This data is also spot-checked against the on-site meter used by the power purchaser to calculate amount of electricity delivered to the grid. Monthly utility bills for the Clinton Landfill operations will be used to determine the quantity of grid electricity used for the Project. Responsibilities All generator data is the responsibility of the DeWitt Energy staff. Generator data quality The kilowatt-hour meters are calibrated on-site every three to six months by the electric utility buying the power. Waste disposal data

The Clinton Landfill tracks the total weight of waste accepted on a daily basis. This data is aggregated and reported to the Illinois Environmental Protection Agency. Data is derived from the scale records; each vehicle is weighed as it enters the facility and as it leaves. This data will be used to model the total amount of methane generated by the landfill each year, as required for the second validation period as appropriate at that time. Overall data integration and quality

DeWitt Energy uses customized software for this Project to aggregate performance data and track performance on an hourly, daily, and weekly basis. Data is accessible both on computers located at the Project facility and via a web-based reporting tool. If any issues are found in the data, corrective action can be taken immediately. TerraPass will be collecting interim data submissions from all parties to flag any potential problems, and will collect and prepare all data for verification.



3.3 Data and parameters monitored / Selecting relevant GHG sources, sinks and reservoirs for monitoring or estimating GHG emissions and removals:

Data and parameters not monitored

Data / Parameter: Regulatory requirements relating to landfill gas projects Data unit: --Description: Regulatory requirements relating to landfill gas projectsSource of data: Publicly available information of United States’ and State of

Illinois’ regulatory requirements relating to landfill gas. In particular, the landfill is regulated under Title 35 Illinois Administrative Code (35 IAC), Subtitle G: Land Pollution (Regulations) and under the Title V Clean Air Act Permit Program. The DeWitt energy plant is also regulated under Title 40 Code of Federal Regulations. In addition, we will also monitor new legislation, such as any regulations pertaining to climate change mitigation.

Measurement procedure:

Any comment: The information though recorded annually, is used for changes to the adjustment factor (AF) or directly MDBL,y at renewal of the credit period. Relevant regulations for LFG project activities shall be updated at renewal of each credit period. Changes to regulation should be converted to the amount of methane that would have been destroyed/combusted during the year in the absence of the project activity (MDBL,y). Project participants should explain how regulations are translated into that amount of gas.

Data / Parameter: GWPCH4

Data unit: tCO2e/tCH4

Description: Global warming potential of CH4

Source of data: IPCC

Measurement procedure: 21 for the first commitment period. Shall be updated according to any future COP/MOP decisions.

Any comment:



Data / Parameter: DCH4

Data unit: metric tons CH4/ft3

Description: Methane density

Source of data: U.S. EPA conversion factor, “Basic Concepts in Environmental Science,”10 Conversion Factors, Volume (Gas) @ STP

Measurement procedure: Density is 0.0000189 metric tons CH4 / ft3 as measured in U.S. units per gas industry standard temperature and pressure: 1 atmosphere and 68o F

Any comment: The EPA lists the volume of 1 lb mole of a gas as 385.4 cubic feet at standard temperature and pressure. To compute density, that volume must be divided into the molar weight of methane, which is 16.042511. 16.0425 divided by 385.4 is 0.0416 lbs/ft3. Dividing this by the number of pounds per metric ton (2204.6) yields a density of 0.0000189 metric tons per cubic foot.

Data / Parameter: BECH4,SWDS,y

Data unit: tCO2e

Description: Methane generation from the landfill in the absence of the Project activity at year y

Source of data: Calculated as per the “Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site”

Measurement procedure: Calculated

Any comment: Used for ex-ante estimation of the amount of methane that would have been generated in a given year, as well as to establish baseline scenario reductions

Data / Parameter: BEy

Data unit: tCO2eDescription: Methane destroyed by the Project less methane destroyed in the

baseline scenario; can also be thought of as creditable methane emissions captured.

Source of data: (MDproject,y – MDBL,y) * GWPCH4


Any comment:

10 http://www.epa.gov/apti/bces/reference/reference.htm 11 http://www.nationmaster.com/encyclopedia/Methane



Data / Parameter: Emissions in the Baseline Scenario in year y

Data unit: tCO2eDescription: Emission of the landfill in year y, in the Baseline Scenario. Source of data: (MGy – MDBL,y) * GWPCH4


Any comment:

Data / Parameter: MDBL,y

Data unit: tCH4

Description: Amount of methane destroyed in the Baseline Scenario for a year y Source of data: MDBL,y = εBL * MGy


Any comment: See calculation tables in PDD

Data / Parameter: MDProject,y

Data unit: tCH4

Description: Amount of methane destroyed in the Project scenario in year y Source of data: At verification: MDelectricity,y + MDFlared,y

At validation, per ACM0001, use ex ante estimation: (BECH4,SWDS,y/GWPCH4 ) * (1 - AFy)

Measurement procedure: Calculated Any comment: See PD for table of ex-ante estimated values. MDFlared,y is assumed to

be 0 for the ex ante estimation, because the flare will only be used when both engines are down for maintenance for a significant period of time. In the first year of operation, the flare was never used.

Data / Parameter: MGHist,y

Data unit: tCH4

Description: Amount of methane generated in a previous year y Source of data: Calculated per the “Tool to determine methane emissions avoided from

dumping waste as a solid waste disposal site” Measurement procedure: Calculated

Any comment: MGHist is used to estimate destruction efficiency of baseline and Project scenarios. See PD for values.



Data / Parameter: MGy

Data unit: tCH4

Description: Amount of methane generated in calendar year y by the landfill in absence of any collection system.

Source of data: Calculated per the “Tool to determine methane emissions avoided from dumping waste as a solid waste disposal site”

Measurement procedure: Calculated Any comment: See PD for values

Data / Parameter: εPR,y

Data unit: Ratio or percent Description: Destruction efficiency of the system used in the Project scenario for

year y Source of data: Prior to verification, pro forma assumptions are used for ex ante

estimation of emissions reductions. At verification, will be calculated as ratio of methane destroyed to methane generated.

Measurement procedure: Calculated Any comment: Value rises from 0.5 to 0.8, based on landfill closure status. These

figures are consistent with U.S. EPA’s “Landfill Gas-to-Energy Project Development Handbook” guidance

Data / Parameter: εBL

Data unit: Ratio or percent Description: Destruction efficiency of the system in the baseline scenario Source of data: Value is calculated based on records of methane destruction in the

year prior to Project start and calculation of total methane generated during the same period, and has been found to be 17.1%.

Measurement procedure: Calculated Any comment:

Data / Parameter: AFy

Data unit: Ratio or percent Description: Adjustment factor indicating the ratio of the baseline destruction

efficiency to the Project destruction efficiency in year y Source of data: Value is calculated by dividing εBL by εPR,y


Any comment: 34.1% for ex ante calculations. Will be recalculated based on first-year project results.



Data / Parameter: MDelectricity,y

Data unit: tCH4

Description: Quantity of methane destroyed at the power plant Source of data: LFGelectricity,y * WCH4,y * DCH4


Any comment: Not used in ex ante calculations.

Data / Parameter: MDflared,y

Data unit: tCH4

Description: Quantity of methane destroyed in the flare Source of data: LFGflare,y * WCH4,y * DCH4 – (PEflare,y/GWPCH4) Measurement procedure: Calculated

Any comment: Not used in ex ante calculations. The back-up flare is not presently hooked up to to landfill gas collection system, so monitoring and calculation of this value is not planned at this time.

Data / Parameter: PEflaredy

Data unit: tCO2

Description: Project emissions from flaring of the residual gas stream in year y Source of data: LFGflare,y * WCH4,y * DCH4 * (1 - ηflare) * GWPCH4 Measurement procedure: Calculated

Any comment: Not used in ex ante calculations.

Data / Parameter: ηflare

Data unit: Percent Description: Destruction efficiency of an open flare Source of data: Default value from the “Tool to determine project emissions from

flaring gases containing methane”

Measurement procedure: NA

Any comment: Not used in ex ante calculations. Taken as 50% in subsequent calculations where needed.

Data / Parameter: PEy

Data unit: tCO2e Description: Project emissions from fossil fuel and grid electricity consumption Source of data: PEEC,y + PEFCy + PECH4,y


Any comment: PEEC,y is assumed to be 0 for ex ante calculations; it will be monitored for ex post calculations



Data / Parameter: PEFC,y

Data unit: tCO2e Description: Project emissions from fossil fuel combustion (flare pilot light) in year

y Measurement procedure: NA Any comment: This parameter will not be monitored because the flare exists in the

baseline scenario, so the pilot light isn’t attributable to Project activities and is taken as 0

Data / Parameter: PEEC,y

Data unit: tCO2e Description: Project emissions from grid electricity consumption Source of data: ECPJ,y * CEFelecy,BL,y * (1+TDLy)


Any comment: Close to zero, because project generates its own electricity. Utility bills will be used to monitor any grid electricity consumption.

Data / Parameter: PECH4,y

Data unit: tCO2e Description: Project methane emissions (landfill plus flaring) in year y Source of data: (MGy – MDProject,y) * GWPCH4


Any comment:

Data / Parameter: CEFelecy,BL,y

Data unit: tCO2/MWh Description: Carbon emission factor of electricity Source of data: Conservative default value provided by the “Tool to calculate baseline,

project and/or leakage emissions from electricity consumption” Measurement procedure: NA

Any comment: Standard value of 1.3 used, in accordance with Option A2 of the “Tool to calculate baseline, project and/or leakage emissions from electricity consumption.” The Project meets the following criterion described in the tool: “Scenario A applies to: both baseline and project (and/or leakage) electricity consumption sources; and the electricity consumption of the project and leakage sources is greater than the electricity consumption of the baseline sources.”



Data / Parameter: TDLy

Data unit: percent Description: Transmission and distribution losses attributable to the use of local grid

electricity Source of data: U.S. Energy Information Administration “2007 Annual Energy

Review”12

Measurement procedure: NA Any comment: Value of 9% used, based on a study by the U.S. Energy Information

Administration. The EIA releases an update every few years. TerraPass will monitor these updates and use the most recent figures available.

Data / Parameter: ERy

Data unit: tCO2e Description: Creditable emission reductions year y in the Project scenario Source of data: BEy - PEy

Measurement procedure: Calculated Any comment: See table of values in PDD.

Data and parameters monitored

Data / Parameter: LFGelectricity,y

Data unit: ft3

Description: Amount of landfill gas combusted in power plant at normal temperature and pressure

Source of data:

Measurement procedure: Measured by a flow meter. Data to be aggregated monthly and yearly

Monitoring frequency: Continuous

QA/QC procedures: Annual calibration by factory-authorized technician

Any comment: Not used for ex ante calculations.

12 http://www.eia.doe.gov/emeu/aer/pdf/aer.pdf, p. 62



Data / Parameter: LFGtotal,y

Data unit: ft3

Description: Total amount of landfill gas combusted in power plant at normal temperature and pressure

Source of data:

Measurement procedure: Measured by a flow meter. Data to be aggregated monthly and yearly



Any comment: Because flare is not connected to gas collection system at present time, this figure is equal to LFGelectricity,y

Data / Parameter: T

Data unit: ºF

Description: Temperature of landfill gas Source of data: Project participantsMeasurement procedure: Measured to determine the density of methane. No separate monitoring

of temperature is necessary when using flow meters that automatically measure normalized volume.



Any comment:

Data / Parameter: P

Data unit: Atmospheres

Description: Pressure of landfill gas Source of data: Project participantsMeasurement procedure: Measured to determine the density of methane. No separate monitoring

of pressure is necessary when using flow meters that automatically measure normalized volume.



Any comment:



Data / Parameter: WCH4

Data unit: ft3 CH4 / ft3 LFG

Description: Methane fraction in landfill gasSource of data: To be measured weekly by project participants using a handheld gas

analyzer, such as a Landtec GEM-2000 or Elkins Earthworks Envision

Measurement procedure: Shall be measured using equipment that can directly measure methane content in the landfill gas,

Monitoring frequency: Weekly

QA/QC procedures: Field calibration before every use, plus annual factory calibration

Any comments: For baseline calculation, a methane fraction of 59.8% was used, based on a statistical analysis of monitoring records from 2006 (see Annex 5). For ex ante calculation, a value of 50% was used, reflecting a standard value for landills. Note that the fraction doesn’t matter for ex ante calculations, because the ex ante emissions reductions are based on a decay model, not on a measure of landfill gas.

Data / Parameter: ECPJ,y

Data unit: Megawatt-hours

Description: Quantity of grid electricity used by Project equipmentSource of data: Energy bills delivered to DeWitt Energy Associates

Measurement procedure: Collect utility bills each month

Monitoring frequency: Monthly

QA/QC procedures:

Any comment:

Data / Parameter: Operation of the energy plant

Data unit: HoursDescription: Operating hours of the energy plantSource of data: Project participants

Measurement procedure: Records of engine uptime

Monitoring frequency: DailyQA/QC procedures: Any comment: Not needed for ex ante estimation. This is monitored to ensure

methane destruction is claimed for methane used in electricity plant when it is operational.



Data / Parameter: ELLFG

Data unit: MWh Description: Net amount of electricity generated using LFG. Source of data: Project participants

Measurement procedure: Electricity meter Monitoring frequency: Continuous

QA/QC procedures: Electricity meter will be subject to regular (in accordance with stipulation of the meter supplier) maintenance and testing to ensure accuracy.

Any comment: Not needed for ex ante estimation. Electricity production is monitored to establish the operating hours of the Project

Data / Parameter: Wx

Data unit: Metric tonsDescription: Total amount of waste disposed at the landfillSource of data: Landfill scale readings

Measurement procedure: Each truck’s contents are weighed at the landfill scale. Quarterly and yearly totals are reported to the State

Monitoring frequency: Annually

QA/QC procedures:

Any comment: Distribution of organic vs. non-organic waste types are as noted below in variable p

The following parameters are not monitored and are part of the ”Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site”:

Data / Parameter: φ

Data unit: -

Description: Model correction factor to account for model uncertaintiesValues to be applied: 0.9

Any comment: Oonk et el. (1994) have validated several landfill gas models based on 17 realized landfill gas projects. The mean relative error of multi-phase models was assessed to be 18%. Given the uncertainties associated with the model and in order to estimate emission reductions in a conservative manner, a discount of 10% is applied to the model results. 13

13 Oonk H., Weenk A., Coops O., Luning L. (1994) Validation of landfill gas formation models; EWAB 9427; NOVEM, Utrecht, The Netherlands



Data / Parameter: OX

Description: Oxidation factor (reflecting the amount of methane from SWDS that is oxidized in the soil or other material covering the waste)

Source of data: Site visit

Values to be applied: Use 0.1 for managed solid waste disposal sites that are covered with oxidizing material such as soil or compost. Use 0 for other types of solid waste disposal sites. Figures are taken from the CDM “Tool to determine methane emissions avoided from disposal of waste at a solid waste disposal site”, version 4, page 3.

Any comment: We will use a value of 0, because the Clinton Landfill is covered with 60-mil high density polyethylene liner.

Data / Parameter: F

Data unit: - Description: Fraction of methane in the SWDS gas (volume fraction)Source of data: IPCC 2006 Guidelines for National Greenhouse Gas Inventories

Values to be applied: 0.5

Any comment: This factor reflects the fact that some degradable organic carbon does not degrade, or degrades very slowly, under anaerobic conditions in the SWDS. A default value of 0.5 is recommended by IPCC.

Data / Parameter: DOCf

Data unit: - Description: Fraction of degradable organic carbon (DOC) that can decomposeSource of data: IPCC 2006 Guidelines for National Greenhouse Gas Inventories

Values to be applied: 0.5

Any comment:

Data / Parameter: MCF

Data unit: - Description: Methane correction factorSource of data: IPCC 2006 Guidelines for National Greenhouse Gas Inventories

Values to be applied: 1.0 for anaerobic managed solid waste disposal sites as per guidance in the “Tool to determine methane emissions avoided from disposal of waste at a solid waste disposal site”

Any comment: The methane correction factor (MCF) accounts for the fact that unmanaged SWDS produce less methane from a given amount of waste than managed SWDS, because a larger fraction of waste decomposes aerobically in the top layers of unmanaged SWDS.



Data / Parameter: Pn,j,x

Data unit: Weight fraction of the waste type j Description: Used in ex ante calculations of the emissions of the landfill in the

baseline scenarioSource of data: Sampling conducted by Iowa Department of Natural Resources and

reported in a 2006 report entitled “Iowa Statewide Waste Characterization Study”14

Values to be applied: Waste Type % by weight Wood and wood products 10.4 Pulp, paper, cardboard (not sludge) 33.0 Food, food waste, bev & tobacco 10.6 Textiles 4.9 Garden, yard and park waste 3.1 Glass, plastic, metal, other inert 38.0

Any comment: Iowa borders on Illinois and has a similar climactic and demographic profile

Data / Parameter: DOCj

Description: Fraction of degradable organic carbon (by weight) per waste typeSource of data: IPCC 2006 Guidelines for National Greenhouse Gas Inventories

Values to be applied: Waste Type DOC - % dry waste Wood and wood products 50 Pulp, paper, cardboard (not sludge) 44 Food, food waste, bev & tobacco (not sludge) 38 Textiles 30 Garden, yard and park waste 49 Glass, plastic, metal, other inert 0

Any comment: See Annex 1 for a discussion of this parameter

14 http://publications.iowa.gov/3976/



Data / Parameter: ki

Data unit: - Description: Decay rate per waste type iSource of data: IPCC 2006 Guidelines for National Greenhouse Gas Inventories,

Volume 5, Table 3.3Values of data applied: Waste Type k

Wood, wood products, straw 0.03 Pulp, paper, cardboard (not sludge), textiles 0.06 Other (non-food) organic putrescible garden and park waste 0.1 Food, food waste, sludge, bev & tobacco 0.185

Any Comments: At Clinton, the climatic conditions are as follows: Mean Avg. Temp = 11.5o C (NOAA 30-year normals)15 Mean Avg. Precip = 90.3 cm (NOAA 30-year normals)16 Potential Evapotranspiration = 63.6 cm (Thornthwaite method17) MAP/PET = 1.420

Boreal/Temperate, Wet

15 http://www.ncdc.noaa.gov/oa/climate/online/ccd/meantemp.html 16 http://www.ncdc.noaa.gov/oa/climate/online/ccd/nrmpcp.txt 17 Source equation from: Botkin, D.B. Forest Dynamics: An Ecological Model. Oxford

University Press, 1993.



3.4 Description of the monitoring plan

Parameter Data source Frequency Party NotesNormalized flow to generators

Continuous flow meter

Captured continuously and aggregated hourly, daily, and weekly

DeWitt Energy operations technician

Log will be submitted periodically to TerraPass

Total landfill gas captured (normalized)

Continuous flow meters

Captured continuously and aggregated hourly, daily, and weekly


Log will be submitted periodically to TerraPass

Landfill gas temperature


Captured continuously and aggregated hourly, daily


Flow readings may be normalized to standard temperature and pressure by flow meter, in which case temperature won’t be recorded separately

Landfill gas pressure


Captured continuously and aggregated hourly, daily

Landfill operations personnel

Flow readings may be normalized to standard temperature and pressure by flow meter, in which case pressure won’t be recorded separately

Operating hours of the generators; total electricity generated

Kilowatt-hour meters

Hourly DeWitt Energy operations technician

Logs will be used by TerraPass at verification to ensure no flow is credited when generators are not operating

CH4 % Handheld meter such as Landtec GEM-2000 or Elkins Earthworks Envision

At least weekly DeWitt Energy operations technician

Field calibration records also kept

Waste Disposed

Scale readings as submitted to Illinois Environmental Protection Agency

Annually Landfill operations personnel

TerraPass will collect this data annually

Grid electricity used by Project

Electricity bills to DeWitt Energy

Monthly DeWitt Energy operations technician



The following chart provides a summary of equipment calibration plan. Equipment Calibration procedure Frequency Responsible party Continuous flow meter

Calibration Annually Factory-authorized representative

Generator kilowatt-hour meter

Calibrate per manufacturer instructions

Once every 3-6 months

Ameren

Handheld gas constituent analyzer

Field calibrate against reference gas cylinder, record results

Daily prior to use DeWitt Energy operations technician

Handheld gas constituent analyzer

Factory calibration Annually Factory-authorized representative

Responsibilities and processes

DeWitt Energy has overall responsibility for data collection and quality assurance. Training procedures for monitoring process are the following:

1. Creation of a manual detailing monitoring procedures, recordkeeping requirements, and equipment use, similar to the safety and employee manuals DeWitt already has in place for Project personnel.

2. Use of manual as the basis for training sessions prior to the start of official project monitoring, as well as regular updates to the manual and refresher training sessions as required by equipment or process changes.

DeWitt already keeps extensive records on hundreds of pieces of equipment and operating parameters. These data are logged on a routine basis (many operating parameters are logged hourly) and entered into a custom software tool which aggregates the data in an online database and generates periodic reports. This same software tool will be used to capture the monitoring parameters for carbon credit verification. Data will be submitted to TerraPass in electronic format on a quarterly basis. TerraPass will perform an additional quality assurance check when data is received, ensuring both that the data set is complete and flagging any anomalous values. After any quality issues are raised with the landfill and resolved, TerraPass will store the data in a standardized database format (Microsoft Access) for use in calculating emissions reductions.



4 GHG Emission Reductions

4.1 Explanation of methodological choice:

The GHG emission reduction calculations follow ACM0001. TerraPass developed the baseline scenario calculations and ex ante estimates of Project reductions in January 2009, using data supplied by Clinton Landfill and DeWitt Energy Associates. The baseline scenario assumes continued collection of landfill gas using the equipment in place prior to the installation of the Project and combusted using the open flare. Calculation of a baseline emissions scenario is necessary both to make an ex ante estimate of future reductions and to establish an adjustment factor (AFy) for crediting of Project emissions reductions. TerraPass performed a baseline calculation for the Project in December 2008 according to the following steps:

1) Using historical data from the year prior to the installation of the Project, we establish how many metric tons of methane were destroyed using the open flare (MDHist).

2) Using the first-order decay model described in the “Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site,” we estimate the total amount of methane generated by the landfill in the year prior to the installation of the Project (MGHist). Emissions in the baseline scenario are equal to MGHist minus MDHist.

3) We use these figures to calculate the destruction efficiency for the baseline gas collection system (εBL).

4) During the first verification, we calculate the methane destroyed in the first year of the Project’s operation, using Project performance data (MDProject,1).

5) Again using the first-order decay model, we determine the total methane generated during the first year of Project activity (MGProject,1).

6) These figures are used to derive the Project destruction efficiency (εPR,1). 7) Landfill emissions change over time as the waste mass decays, and the number of

wells in the baseline scenario likewise changes as more waste is added to the landfill. To project the calculated emissions in the baseline scenario into the future, we calculate an adjustment factor AFy equal to εBL divided by εPR,y. AFy represents the percentage of destroyed methane that would have been destroyed in the baseline scenario.

8) During verification, the adjustment factor is applied to the amount of methane destroyed by Project activity in the previous year to determine the number of creditable tons.

Note that the gas collection system will undergo upgrades over time, and that many of these upgrades would have occurred in the baseline scenario. Because the adjustment factor represents the relative destruction efficiencies of the baseline and Project scenarios,



applying to the adjustment factor to future methane destruction allows us to adjust the baseline reductions upward as appropriate. Per the ACM0001 methodology, the adjustment factor can be recalculated in future years. TerraPass plans to recalculate when the new monitoring plan is in place. For the first verification, we will use electricity generation records to calculate the amount of methane destroyed by Project activity.

4.2 Quantifying GHG emissions and/or removals for the baseline scenario:

Calculations of historical methane destroyed

To determine the emissions in the baseline scenario for every year y of the crediting period, we will take the actual emissions from one historic year, and project it forward based on the ex-post calculation of the destruction efficiency of the baseline system, where the destruction efficiency is defined as:

εBL = MDHist / MGHist (3) The first term we must define is MDHist, the amount of methane destroyed historically measured for the previous year before the start of the project, in metric tons of CH4. In our case, the amount of methane destroyed in the baseline scenario is not numerically defined by a regulation or a contract. Therefore, we will use historic monitoring data on the actual amount of methane captured and destroyed in the open flare in 2006. According to the “Tool to determine project emissions from flaring gases containing methane,” the following equation is used to calculate the destruction of methane in an open flare:18

MDflare,y = LFGflare,h * WCH4,h * DCH4 – PEflare,y/GWPCH4 where PEflare,y = LFGflare,h * WCH4,h * DCH4 * (1 – η) * GWPCH4 therefore MDflare,y = LFGflare,h * WCH4,h * DCH4 * η LFGflare,h = quantities of landfill gas fed to the flare WCH4,h = methane concentration

18 This equation has been modified to calculate the methane destroyed, rather than methane emitted. Also,

the GWP term has been dropped so that result is in tCH4 rather than tCO2e. Finally, the term for units conversion to metric tons has been dropped, and will instead be accounted for in the density figure used.



DCH4 = methane density in metric tons per cubic foot η = flare efficiency factor

According to the tool, a default destruction efficiency of 50% should be used for open flares when the flare is in operation, and an efficiency of 0% when the flare is not in operation. We will make the conservative assumption that the flare was operational all the time, and use an efficiency of 50%. Most U.S. measurements of gas flow define standard temperature and pressure as 68º F and 1 atmosphere. ACM0001 provides a methane density figure of 0.0007168 metric tons per cubic meter. However, this figure derives from a standard temperature of 0º C. Since measurements at Clinton Landfill are taken at the U.S. standard of 68º F, we will use the methane density provided by the U.S. EPA for this case: volume of 1 gm lb mole of ideal gas at STP = 24.04385.4 litersft3.19 This converts as follows:

16.0425 lbs CH4/mol * (1 metric ton CH4/2204.6 lbs CH4) * 1 mol/385.4 ft3 = 0.0000189 metric tons CH4 per ft3

Baseline gas capture and destruction is based on a series of weekly flow and monthly methane concentration data taken over the entire course of 2006. A complete description of the data set and the calculations performed to determine baseline methane capture appears in Annex 5. Using this historic monitoring data, we arrive at the following value for MDHist:

Baseline scenario, methane destroyed in 2006 Methane collected 3,899 metric tons

Destruction efficiency η 50% MDHist,2006 1,949 tCH4

Calculation of historical methane generated

Next, we calculate MGHist, the amount of methane the entire landfill generated in 2006, the year prior to the Project start. We use the first-order decay model described in the “Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site.” The model takes a number of inputs, which are described fully in Annex 1.

Baseline scenario, methane generated MGHist,2006 12,683 tCH4

Calculation of baseline destruction efficiency

MDHist, taken together with MGHist, can be used to calculate the destruction efficiency εBL of the baseline system:

19 http://www.epa.gov/apti/bces/reference/reference.htm



εBL = MDHist / MGHist (3) = 1,949 / 12,683 = 15.4%

With this efficiency factor, we can estimate MDBL,y for any year y: MDBL,y = εBL * MGy MDBL,y = 0.171 * MGy So that finally, Emissions in the baseline scenario for any year y = (MGy – MDBL,y) * GWPCH4 = MGy * (1 - 0.171) * 21 Note that these baseline emissions calculations use a constant destruction efficiency over time, which is not a realistic assumption. As more of the landfill is placed under final cover and additional gas collection wells are added, destruction efficiency will rise. Such fluctuations are handled during verification by applying the adjustment factor AFy, which causes changes in the Project destruction efficiency to be mirrored in the baseline. Emissions in the baseline scenario

For the baseline scenario, we calculate emissions using ACM0001, as applicable to the scenario in which the Clinton Landfill continues operation of the landfill gas collection system in place prior to development of the Project. In the baseline scenario, emissions are equal to total landfill methane generated less the amount collected and destroyed in the open flare. To calculate the landfill’s emissions, we use the first-order decay model described in the “Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site (version 02),” applying baseline destruction efficiency derived above and using data values described fully in Annex 1.

Baseline emissions, crediting period (metric tons CO2e)

2009 236,367 2010 229,283 2011 210,990 2012 194,669 2013 180,053 2014 166,915 2015 155,064 2016 144,336 2017 134,593 2018 125,716



4.3 Quantifying GHG emissions and/or removals for the project:

ACM0001 requires identification of changes in fossil fuel use, and changes in non-renewable electricity use that occur as a result of the Project. These may result in Project Emissions in addition to those from methane sources such as the landfill. As described in Section 2.3 above, the possible sources of fossil fuel use and non-renewable electricity in this project are as follows:

• The flare has a pilot light that is fueled by a canister of propane. Because the flare is also used in the baseline scenario, this emissions source is not attributed to Project activity, and will not be monitored.

• The gas collection system and energy generation facility at the Project has blowers, valves, gas conditioning equipment, electricity generators and other equipment which could be powered by grid electricity. Although the baseline scenario also includes some electricity consumption for project equipment, we will make the conservative assumption that baseline electricity consumption is zero.

For the most part, Project equipment will be powered by the renewable electricity generated by the Project, except during times that the engines are being maintained or repaired. We will monitor grid electricity use through utility bills for the Project. If grid electricity is used, we will use the default emission factor given in the “Tool to calculate baseline, project and/or leakage emissions from electricity consumption.” This tool provides several scenarios for calculating electricity consumption emissions. Because we are exclusively seeking a calculation factor for grid electricity consumption in the Project scenario, our equation is relatively simple:

PEEC,y = ECPJ,y * CEFelecy,BL,y * (1+TDLy) (1) ECPJ,y = the electricity consumption of the Project sources in year y CEFelecy,BL,y = the grid emission factor for the local electricity grid in year y TDLy = the transmission and distribution losses in year y

ECPJ,y will be determined through electricity bills. For CEFelecy,BL,y, we refer to the tool, “Scenario A: Electricity Consumption from the Grid.” We then have two options to determine a grid electricity emissions factor, and we choose to use Option A2, a conservative default value, because situation (a) applies: the grid electricity consumption applies only to project electricity sources, not baseline electricity sources. The conservative default value provided by the tool is 1.3 tCO2/MWh.



For TDLy, we use recent data from the U.S. Energy Information Administration. Specifically, we use the 9% figure from the 2007 Annual Energy Review.20 Therefore, equation (1) becomes: PEEC,y in metric tons CO2 = ECPJ,y * CEFelecy,BL,y * (1+TDLy) (1) = (Grid electricity consumption for Project in MWh) * 1.3 tCO2/MWh * 1.09 We will apply this equation to Project electricity use at verification. Project Emissions from the landfill are determined by calculating the landfill methane generated in a given year less the methane destroyed by the Project:

PECH4,y = (MGy – MDProject,y) * GWPCH4 Total Project Emissions in any year are the sum of the emissions from electricity use and methane emissions.

PEu = PEEC,y + PECH4,y

4.4 Quantifying GHG emission reductions and removal enhancements for the GHG project:

See ISO 14064-2: 5.2.k for quantifying GHG emission reductions or removal enhancements.

Ex ante calculation of Project emissions reductions

For the purposes of making an ex ante estimate of Project emissions reductions, we will perform calculations similar to those used to determine emissions in the baseline scenario. ACM0001 recommends using an estimated destruction efficiency for ex ante estimations of the Project reductions. For our ex ante calculations, we will use the pro forma planning assumptions of the Project developer, which take into account the fact that gas collection efficiency is expected to rise as more of the landfill is placed under final cover and the final gas collection wells are installed. The long-term pro forma destruction efficiency of 80% is in line with EPA estimates for typical collection efficiencies. 21 The rising collection efficiency also affects the baseline scenario. To account for this, we first must calculate an adjustment factor for methane destruction:

20 Available at http://www.eia.doe.gov/aer/

See specifically: http://www.eia.doe.gov/aer/pdf/pages/secnote2.pdf 21 Section 2.2.2 of the US EPA’s Landfill Gas to Energy Handbook notes, “A reasonable assumption for a

newer collection system operated for energy recovery is 75 to 85 percent collection efficiency.”



AFy = εBL / εPR,y (7) where εPR,y = MDproject,y / MGproject,y (4)

During verification, we will calculate an actual εPR,1 based on monitored values, but for ex ante calculations, we use the pro forma efficiency in year 1 (50%).

AF1 = 15.4% / 50% = 30.7% Using this adjustment factor, we can calculate methane destroyed in the baseline scenario

MDBL,y = MDproject,y * AFy (2) For ex ante emissions reductions, we will ignore Project emissions from electricity use, which are assumed to be small relative to methane destruction. A review of electricity bills for February, 2007 to December, 2007 shows an average electricity consumption of 1.2 MWh per month, which translates to only 21 metric tons of carbon emissions per year using the grid emissions factors above. These Project emissions will be taken into account during verification. The calculations for emissions reductions are shown below:

ERy = BEy - PEy (17) where BEy = MGy - MDBL,y

Assuming zero emissions from electricity use and fossil fuel consumption:

PEy = MGy – MDproject,y Using the formulae for BEy and PEy as shown above, and substituting for MDBL,y as shown in equation (2) results in the following for ex ante emission reductions: ERy = MDproject,y * ( 1 – AF ) * GWPCH4 Using the same first-order decay model that we applied to the baseline scenario yields the following ex ante greenhouse gas reductions:



Ex ante project emissions reductions

Year εPR,y BECH4,SWDS,y

(mt CO2e) MDproject,y (mt CH4)

ERy (mt CO2e)

2009 61% 236,367 8,146 118,480 2010 61% 229,283 7,902 114,929 2011 65% 210,990 7,717 112,235 2012 73% 194,669 7,952 115,661 2013 80% 180,053 8,105 117,880 2014 80% 166,915 7,514 109,279 2015 80% 155,064 6,980 101,520 2016 80% 144,336 6,497 94,497 2017 80% 134,593 6,059 88,118 2018 80% 125,716 5,659 82,306

Calculating Project reductions at verification

Calculating emissions reductions at verification is analogous to the ex ante calculations, except that monitored values are used to derive the methane quantities destroyed and destruction efficiencies. The following equations are needed:

ERy = BEy - PEy (17) BEy = (MDproject,y - MDBL,y) * GWPCH4 MDBL,y = MDproject,y * AFy (2) AFy = εBL / εPR,y (7) εPR,y = MDproject,y / MGy (4) εBL = MDHist / MGHist (3)

ERy represents the calculated emissions reductions in year y. Project emissions in year (PEy) are calculated as in Section 4.3. The baseline emissions in year y (BEy) are calculated by subtracting methane destroyed in the baseline scenario (MDBL,y) from methane destroyed in the project scenario (MDproject,y). MDproject,y is a derived value, typically based on gas flow and methane concentration data. MDBL,y is in turn calculated by applying the adjustment factor AFy to MDproject,y. AFy is based on the measured destruction efficiencies (ε) of the baseline and Project scenarios. Destruction efficiencies are calculated by dividing methane destroyed (MD) by methane generated (MG). MD is a measured value. MG is calculated using the first-order decay model, as above. Calculating Project methane destroyed

MDproject,y is equal to the sum of MDelectricity,y, the methane destroyed from electricity generation in year y, and MDflare,y, the methane destroyed from flaring in year y. For the purposes of these calculations it is assumed that little or no methane is passed to the flares



for destruction and is thus ignored, a conservative assumption. In the instance of significant methane destruction by flaring, MDproject,y will be altered accordingly to reflect this methane destruction. In future years, MDelectricity,y will be calculated using measured gas flow and methane fraction data:

MDelectricity,y = LFGelectricity,y * WCH4,y * DCH4 (10)



5 Environmental Impact A summary environmental impact assessment when such an assessment is required by applicable legislation or regulation

No environmental impact assessment is required for the Project activity.



6 Stakeholders comments Relevant outcomes from stakeholder consultations and mechanisms for on-going communication.

DeWitt Energy has made a variety of efforts to reach out to both local leaders and the community at large. The purpose of this outreach has been to explain the benefits of the project to the public, to respond to questions and feedback, and to help ensure compliance with safety standards. Outreach efforts include the following activities:

• Edwin Ingalls, General Manager of DeWitt Energy, met with the county zoning board in the spring of 2005 to explain the project and answer questions.

• DeWitt Energy twice hosted the fire chief and fire department for site visits during construction, to familiarize local emergency personnel with the design of the system.

• Ingalls presented the project to the Rotary Club, an association of local business leaders, prior to the project start date.

• After project start, Ingalls presented the project to the Central Illinois Mayor’s Association.

• Ingalls has also made several local press appearances, including articles in the Clinton Daily Journal and a twenty-minute radio interview on WHOW.

Separately, the Project was subject to the extensive public consultation processes required by U.S. law. The United States has a longstanding tradition of public stakeholder consultation prior to granting environmental permits at the federal, state and municipal level. Typically, this includes measures to alert the public about the project and ways to participate, through advertisements in relevant local media, town hall style meetings or other public hearings, an on-line option for offering comments and easy access to officials through postal mail and/or phone. This Project’s generators and flare required air quality permits pursuant to the U.S. Clean Air Act as sources of NOx, and therefore this Project was subject to Clean Air Act permitting and notice requirements. Those requirements are described in Annex 2. These outreach efforts did not yield any significant feedback from the community. A landfill gas collection and flaring system was already in place at the landfill at the time that the project was developed, and the addition of a gas-to-energy plant at the site, financed by a private developer, was generally regarded as an uncontroversial and even positive community development. No records of feedback from these consultations exist, because no formal feedback was offered.



7 Schedule Chronological plan for the date of initiating project activities, date of terminating the project, frequency of monitoring and reporting and the project period, including relevant project activities in each step of the GHG project cycle.

Project agreement reached between DeWitt Energy and Clinton Landfill: February, 2004

Accept financing from bank December, 2005 Engines arrive April, 2006 Project online (start) date February, 2007 Project Activity VCS Validation March, 2009 VCS-compliant monitoring start date July, 2009 Crediting period start date July, 2009 Project Activity VCS Verification May, 2010 (every 12 months) Project monitoring start date Spring, 2009 Project Activity VCS Re-Validation January, 2017 Project Termination Unknown The generators are expected to operate for several decades. The end-of-life for the project will likely be determined by the availability of sufficient gas to justify ongoing operation of the equipment. Landfill gas is expected to peak soon after the closure of the landfill in 2009 and then taper down slowly over several years. The formal monitoring plan is described in Section 3.4. Monitoring is conducted on an ongoing basis onsite; data will be forwarded at least quarterly to TerraPass following validation, and approved verifiers will review monitoring data every twelve months.



8 Ownership

8.1 Proof of Title

• Provide evidence of proof of title through one of the following:

• a legislative right; • a right under local common law; • Ownership of the plant, equipment and/or process

generating the reductions/removals; • A contractual arrangement with the owner of the plant,

equipment or process that grants all reductions/removals to the proponent

The contract between TerraPass and Clinton Landfill is attached as Annex 4.

8.2 Projects that reduce GHG emissions from activities that participate in an emissions trading program (if applicable):

Project proponents of projects that reduce GHG emissions from activities that:

• are included in an emissions trading Program; or • take place in a jurisdiction or sector in which binding

limits are established on GHG emissions; shall provide evidence that the reductions or removals generated by the project have or will not be used in the Program or jurisdiction for the purpose of demonstrating compliance. The evidence could include:

• a letter from the Program operator or designated

national authority that emissions allowances (or other GHG credits used in the Program) equivalent to the reductions/removals generated by the project have been cancelled from the Program; or national cap as applicable or;

• purchase and cancellation of GHG allowances equivalent to the reductions/removals generated by the project related to the Program or national cap.

This project’s emission reductions are not included in an emissions trading Program and do not take place in a jurisdiction or sector where binding limits are established on the project’s GHG emissions.



Annex 1: Key methane generation inputs and assumptions

Decay model

To estimate the ex ante emissions and calculate emissions in the baseline scenario, TerraPass uses a first-order decay model that implements the equations in the CDM “Tool to determine methane emissions avoided from dumping waste at a solid waste disposal site (version 04) (EB41, annex 10).” To complete the model, we use publicly available data sets for typical conditions in the relevant geographical area.

Geographical parameters State Illinois

Nearest city Springfield Mean average temperature (ºC) 11.5

Mean average precipitation (cm) 90.3 Potential evapotranspiration (cm) 63.6

MAP/PET 1.4 Climate zone Boreal and Temperate

Moisture zone Wet

Methane production parameters Landfill management type Managed anaerobic

Landfill covering 60-mil high density polyethylene liner OX (oxidation factor) 0%

MCF (methane correction factor) 1 Is the landfill wet or dry? Dry

F (fraction of methane in the SWDS gas) 50% f (fraction of methane captured) 80%

Pn,j,x (waste fraction of waste type j)

Wood and wood products 10% Pulp, paper and cardboard 33% Food, beverages, tobacco 11%

Textiles 5% Garden, yard, park waste 3%

Glass, plastic, metal, inert waste 38% We derive our waste composition figures from a study published in 2006 by the Iowa Department of Natural Resources.22 Iowa shares a border with Illinois and has a similar climactic and demographic composition. To map the waste categories in the Iowa study to those used in the CDM tool, we treat the “Other inorganic” category as garden waste, and diapers as inert waste.

22 http://publications.iowa.gov/3976/1/wastechar05.pdf, Table 1-1, section 1, pages 2-4. Note that we consolidated “total wood” and “fines/super mix” for our “wood and wood products” category; and “total yard waste” and “other organics” for our “garden, yard, park waste” category.



Wx (waste accepted per year, metric tons) 1990 238,219 2000 251,283 1991 238,219 2001 243,339 1992 238,219 2002 242,758 1993 238,219 2003 250,074 1994 190,901 2004 258,069 1995 279,990 2005 254,235 1996 196,617 2006 272,276 1997 198,631 2007 238,119 1998 208,793 2008 238,219 1999 249,975 2009 119,109

Waste quantity data is derived from regulatory filings with the Illinois EPA that have been compiled in publicly available annual reports.23 However, these reports only go back to 1994, and the Clinton Landfill began accepting waste in 1990. Because the amount of waste accepted per year has been fairly steady over time, we take an average to fill in the missing years. Note that these interpolated figures will affect both the numerator and denominator of the adjustment factor roughly equally, and so even large deviations from reality have little effect on the values used for determining emissions credits. For example, changing the waste disposal rates between 1990 and 1993 by ±50% affects the adjustment factor by less than ±1%.

Discussion of DOCj “Wet” vs. “Dry” Waste

One input to the “Tool to determine methane avoided from disposal of waste at a solid waste disposal site” is DOCj, defined as the fraction of degradable organic carbon by weight in the waste type j. The tool provides differing sets of values for “wet waste” and “dry waste.” These differing inputs help the model correct for varying water content present in the measured weights of waste accepted at a landfill. If the waste has a great deal of water content when it is weighed, then it will have less degradable organic carbon per ton than the same waste with less water. The tool provides no guidance as to which value (wet or dry) to select for a given landfill. According to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, Chapter 2, Table 2.4, which provides the wet and dry DOCj values:

DOC values for different waste types, which are derived from analyses based on sampling during waste collection at SWDS or at incineration facilities, may include impurities, e.g., traces of food in glass and plastic waste. Carbon contents of paper, textiles, nappies, rubber and plastic may also be different between countries and at different time periods. These analyses may therefore result in

23 http://www.epa.state.il.us/land/landfill-capacity/ - This site has links to each of the annual reports. To

find the waste deposit data, select the sub-report for “Region 4: East Central Illinois.” Add in the in-state and out-of-state waste acceptance figures, and then convert from short tons to metric tons.



DOC estimates different from those given in Table 2.4. It is good practice to use DOC values consistently with the way the waste composition data are derived.

Though this explanation is not completely illuminating, it does indicate that the choice should reflect waste’s condition consistent with other waste composition in the model. Two other waste composition data points are relevant here: the waste weight, which is determined at the landfill scale house, and the waste constituents which (for this PD) were determined by a sampling study which grabbed waste samples directly from waste trucks at Iowa landfills. With this guidance, we have chosen to use “dry” waste DOCj values because municipal waste handling in the United States is overwhelmingly accomplished with enclosed waste receptacles and trucks such that climatic conditions are relatively unimportant, and the use of “dry” waste values produce CDM methane generation estimates which are closer to (but still much lower than) methane generation estimates produced by the US EPA’s LandGEM model and submitted to the Illinois Environmental Protection Agency for its air quality operating permit.



Annex 2: U.S. Clean Air Act disclosure requirements

According to the U.S. Clean Air Act, the following processes must be followed regarding public participation in the issuance of permits:

22.107(6) Public notice and public participation.

a. The permitting authority shall provide public notice and an opportunity for public comments, including an opportunity for a hearing, before taking any of the following actions: issuance, denial or renewal of a permit; or significant modification or revocation or reissuance of a permit. b. Notice shall be given by publication in a newspaper of general circulation in the area where the source is located or in a state publication designed to give general public notice. Notice also shall be given to persons on a mailing list developed by the permitting authority, including those who request in writing to be on the list. The department may use other means if necessary to ensure adequate notice to the affected public. c. The public notice shall include the following: (1) Identification of the Title V source. (2) Name and address of the permittee. (3) Name and address of the permitting authority processing the permit. (4) The activity or activities involved in the permit action. (5) The emissions change involved in any permit modification. (6) The air pollutants or contaminants to be emitted. (7) The time and place of any possible public hearing. (8) A statement that any person may submit written and signed comments, or may request a public hearing, or both, on the proposed permit. A statement of procedures to request a public hearing shall be included. (9) The name, address, and telephone number of a person from whom additional information may be obtained. Information entitled to confidential treatment pursuant to section 114(c) of the Act or state law shall not be released pursuant to this provision. However, the contents of a Title V permit shall not be entitled to protection under section 114(c) of the Act. (10) Locations where copies of the permit application and the proposed permit may be reviewed, including the closest department office, and the times at which they shall be available for public inspection. d. At least 30 days shall be provided for public comment. Notice of any public hearing shall be given at least 30 days in advance of the hearing.

e. Any person may request a public hearing. A request for a public hearing shall be in writing and shall state the



person's interest in the subject matter and the nature of the issues proposed to be raised at the hearing. The director shall hold a public hearing upon finding, on the basis of requests, a significant degree of relevant public interest in a draft permit. A public hearing also may be held at the director's discretion. f. The director shall keep a record of the commenters and of the issues raised during the public participation process and shall prepare written responses to all comments received. At the time a final decision is made, the record and copies of the director's responses shall be made available to the public.

g. The permitting authority shall provide notice and opportunity for participation by affected states as provided by subrule 22.107(7).



Annex 3: Clinton Landfill #2 fact sheet

The Illinois Environmental Protection Agency makes data about all of the landfills in Illinois available online. Under the Illinois Solid Waste Management Act, the state compiles an annual report summarizing the remaining capacity and other operational factors. These reports can be found online here: http://www.epa.state.il.us/land/landfill-capacity/ The summary data sheet for the Clinton Landfill #2 from the most recent (2007) report is attached to this PDD.



Annex 4: Contract between TerraPass and DeWitt Energy

The contract between DeWitt Energy Associates and TerraPass is attached to this PDD. The contract serves as proof of ownership of the environmental attributes associated with this Project. The terms of the contract are confidential and should not be made part of the public record.



Annex 5: Baseline methane capture

Description of data set

This historical methane destruction data consists of a series of readings, each containing the following pieces of data:

• Time of reading (hour) • Landfill gas temperature (°F) • Flare temperature (°F) • Flow rate (cubic feet per minute) • Burner pressure (inches H2O) • Barometric pressure (inches Hg)

The intervals between readings vary, averaging 7.1 days with a standard deviation of 1.0 days, for a total of 52 readings in 2006. Essentially, readings were taken on a weekly basis. Methane concentration readings were taken 11 times during the year, at irregular intervals. The average time between readings was 23 days, but the longest gap between measurements was 42 days, and two of the readings were taken on the same day. No methane concentration readings were taken after September.

Data interpolation

Methane concentration

Although methane concentration measurements weren’t taken at regular intervals, the data is remarkably consistent: the average methane concentration across readings is 58.2%, with a standard deviation of only 0.9%. Assuming a normal distribution of measurements, these values indicate that an assumed methane concentration of 59.8% will be higher than the actual methane concentration 95% of the time. Therefore we will use this conservative value as our baseline concentration. Gas volume

To translate gas flow values into gas volumes, we need to calculate both the duration of each reading time period and an average gas flow across that time period. Computing time period duration is straightforward, because time stamps from readings are accurate to the hour. To determine the average gas flow, we take the mean of the two gas flow measurements on either side of the time period. Note that for 9 of the 52 readings, flare temperature was below 500 °C. Periods in which the flare is below 500 °C don’t count for purposes of crediting, but to be conservative, we assume that the flare is running 100% of the time when calculating the baseline.



Gas temperature and pressure

To calculate an average temperature and pressure across time periods, we likewise take the mean of the temperature and pressure readings at the end points of each time period. Of the 52 readings available, one of them was missing temperature data, likely due to a transcription error. As with the methane concentration, we computed an average and standard deviation of all temperature readings to determine the 95th percentile temperature value (in this case, the lower bound is the conservative value), and used that for the missing data point. Note that total pressure is a calculated value, the sum of the barometric and flare pressures converted into common units.

Calculation of methane captured

Because the gas flow readings weren’t taken at standard temperature and pressure, we first computed the equivalent volume at 68 °F and 1 atmosphere using the ideal gas law:

PV = nRT P = pressure in psi V = volume in cubic feet n = lb moles R = universal gas constant (10.73) T = temperature °R

Next we multiplied total gas volume by the methane concentration and the density of methane at standard temperature and pressure (0.00001890 metric tons/cubic foot) to arrive at total tons of methane captured. The calculated value is 3,899 metric tons methane per year.

Equipment specifications

The manufacturer’s rating for the flare capacity is 550 scfm. The manufacturer’s rating for the blower capacity is 600 scfm, with a 25-inch inlet vacuum. Note that for the entire year, the landfill ran the blower and flare above the rated capacity of the equipment, which is to say that they ran the equipment at full power. If we assume a constant flow of 700 cfm, average values for temperature, pressure, and methane concentration, and 100% uptime, the number of tons of methane captured total 4,018 metric tons. The fact that our calculated baseline of 3,899 is close to this theoretical maximum demonstrates that it is a conservative baseline calculation.



Annex 6: analysis of common practice

The following table details all operational landfill gas-to-energy projects in the state of Illinois as presented in the U.S. EPA’s Landfill Methane Outreach Program (LMOP) database.24 Landfills are ordered by increasing waste in place, where data is available.

Landfill City Waste in place (tons) Project type

Generation capacity (MW)

South Barrington S. Barrington 1,000,000 Reciprocating engine 1.6Dixon/GROP #2 Dixon 1,140,780 Reciprocating engine 1.5Lansing Lansing 1,300,000 Reciprocating engine 2.2CDT Rockdale 1,596,000 Reciprocating engine 1.6HOD Antioch 2,000,000 Cogeneration 0.4Upper Rock Island East Moline 2,052,000 Reciprocating engine 4.0Kankakee County Chebanse 2,198,000 Reciprocating engine 1.6Brickyard #1 & #2 Danville 2,301,000 Reciprocating engine 4.0Streator Area #3 Streator 2,500,000 Reciprocating engine 1.9Roxana Edwardsville 3,252,000 Reciprocating engine 2.7Clinton #2 Clinton 3,800,000 Reciprocating engine 3.2Lee County Landfill Dixon 4,030,000 Reciprocating engine 1.5Tazewell County #2 East Peoria 4,049,900 Reciprocating engine 1.6Peoria City/County #1 Brimfield 4,200,000 Reciprocating engine 1.8Land & Lakes/Dolton Dolton 4,202,000 Reciprocating engine 1.5Des Plaines Landfill Des Plaines 5,500,000 Reciprocating engine 3.5Beecher Beecher 5,500,000 Reciprocating engine 2.1Environtech Morris 6,387,000 Reciprocating engine 3.9Countryside Grayslake 6,500,000 Reciprocating engine 7.8Westchester Landfill Westchester 7,000,000 Reciprocating engine 3.5Woodland South Elgin 7,800,000 Reciprocating engine 1.6Lake Northbrook 10,000,000 Gas turbine 9.9Veolia ES Zion Zion 10,000,000 Reciprocating engine 5.4Five Oaks Taylorville 10,200,000 Cogeneration 3.2Land & Lakes #1 & #2 Park Ridge 11,183,620 Reciprocating engine 1.5Settler’s Hill Batavia 13,000,000 Gas turbine 6.0Land & Lakes #3 Chicago 15,000,000 Reciprocating engine 3.5Milam East St. Louis 16,000,000 Reciprocating engine 2.4Greene Valley Naperville 18,707,345 Gas turbine 9.0CID Chicago 21,690,122 Gas turbine 6.6Mallard Lake Hanover Park 24,468,450 Combined Cycle 17.4Sexton #2 Hillside 32,549,715 Gas turbine 12.0Willow Ranch Reciprocating engine 1.0Davis Junction Davis Junction Reciprocating engine 2.0Winnebago Rockford Reciprocating engine 6.4 Landfills with energy projects represent only 25% of landfills designated as good candidates sites by the EPA. Of these 35 landfills with energy projects, only 10 appear to

24 http://www.epa.gov/lmop/proj/xls/opprjslmopdata.xls - accessed April 14, 2009



be smaller than Clinton. Landfill size is a rough proxy for the financial attractiveness of an energy project. The 10 smaller landfills are discussed in turn, noting information relevant to financial and other barriers to implementation. A brief discussion is also given of the Lee County Landfill, which is slightly larger than Clinton. South Barrington Landfill Despite LMOP’s online date of 2001, records indicate that an LFGE project has been operating with LFG from South Barrington Landfill since at least 1997. It was at this point that a 10-year contract was signed to sell electricity to Commonwealth Edison.25 Illinois law required Commonwealth Edison to purchase the electricity for “a duration of not less than 10 years” and “that the purchase price in such contracts be equal to the average price per kilowatt-hour that the unit of local government in which the QSWEF [qualified solid waste energy facility, i.e. the LFGE project] is located pays the utility for electricity.” Thus the South Barrington LFGE project was ensured a long-term price for its electricity that was pegged to retail prices, whereas the price paid for electricity generated by the Clinton landfill project was a negotiated wholesale rate. Dixon / GROP Landfill #2 Landfill gas is collected from the closed Dixon landfill in conjunction with gas collection from the neighboring Lee County landfill, an active site.26 The Lee County landfill currently has over 4 million tons waste in place, giving the project an effective waste in place of over 5.15 million tons, significantly larger than Clinton. Additionally, the Lee County landfill is not set for closure until 2014,27 ensuring that the total waste in place will continue to grow. Lansing Landfill Little information could be obtained about this closed landfill except that it had been sold to a gas recovery plant developer.28 CDT Landfill The CDT landfill is required by law to collect landfill gas due to having exceeded the 50 MG / yr NMOC emission threshold.29 While the LMOP database cites a 1.6 MW capacity, other sources report the power plant having a capacity of 3.2 MW30 and 4.0

25 http://www.icc.illinois.gov/downloads/public/edocket/217458.pdf 26 http://yosemite.epa.gov/r5/il_permt.nsf/

133e3c6aefa1d1638625666a00563357/5b6479e4120cd9f485256db9007481e5/$FILE/ DixonLeeEnergyPartnersSigModProjectSummary.pdf

27 http://www.epa.gov/lmop/proj/xls/opprjslmopdata.xls 28 http://www.co.kendall.il.us/Landfill/Willow%20Run/Exhibits/

070511%20Petitioner%20Exhibit%205.pdf 29 http://www.epa.gov/oalj/orders/cdt10.pdf 30 http://www.algonquinpower.com/business/facility/alternative_cdt.asp



MW capacity,31 indicating that the landfill may be larger than described in the LMOP database. HOD Landfill The HOD Landfill was closed in 1984.32 As an EPA Superfund site, the Federal government has paid for remedial actions, including an active gas collection system,33 thus decreasing capital costs for installing a beneficial use system. Financial barriers have also been removed through a $500,000 State renewable energy grant, electricity sales and an estimated savings of $100,000 for the local school district through reduced heating requirements.34 Upper Rock Landfill Records indicate that the actual amount of waste in place considering all cells of the Upper Rock Landfill exceeds 5 million tons. The NMOC threshold requiring an active landfill gas collection system was exceeded in 2006. The landfill has sought revenue from carbon credits.35 Kankakee County Recycling and Disposal Facility No information could be found regarding this landfill or its energy project beyond that presented in the LMOP database. Brickyard Landfill Records indicate that the total waste in place for the Brickyard Landfill exceeds 6 million tons. Additionally, the landfill project has sought carbon credit revenue.36 Streator Area Landfill Records indicate that the Streator Area Landfill has sought carbon credit revenue.37 Roxana Landfill Roxana Landfill installed a LFGE project in 2001, when the landfill’s then-current permit would have caused it to close in 2007. Roxana had open expansion permits applications on file no later than 2003.38 The site has recently received a new permit allowing it to

31 http://www.ingenco.com/

news_art54_INGENCO%20Executes%20Contract%20to%20Develop%20LFG%20Project%20Near%20Joliet.html

32 http://www.epa.gov/lmop/proj/xls/opprjslmopdata.xls 33 http://www.epa.gov/superfund/programs/recycle/pdf/hodfinalrfr.pdf 34 http://www.edf.org/documents/8713_NOILandfillNSPSOct2008.pdf 35 http://www.ecoregistry.org/account/details/USEBC/ERT_USEBC_Upper_Rock_MRV_2007_08.pdf 36 http://americancarbonregistry.org/carbon-registry/projects/brickyard-landfill-gas-utilization-project/ERT-

USEBC-Brickyard-MRV-2007-07.pdf/at_download/file 37 http://www.americancarbonregistry.org/carbon-registry/projects/streator-landfill-gas-utilization-

project/ERT-USEBC-Streator-MRV-2007-07.pdf/at_download/file 38 http://www.epa.state.il.us/land/landfill-capacity/2002/report.pdf



expand by over 15 million tons.39 Given the long-term planning required in landfills, it is possible that the early LFGE project was made in preparation of required active landfill gas collection and/ or the significant expansion that is now permitted. Lee County Landfill As mentioned, landfill gas is collected from both the Lee County landfill and Dixon Landfill, which are neighboring sites. Additionally, Lee County Landfill was required to install an active gas collection system on or before January 16, 2004.40 Discussion

In summary, most of the landfills seemingly comparable to Clinton face extenuating circumstances that make their projects more desirable than they otherwise would be:

• Two (South Barrington, HOD) benefited from favorable financial terms. • Four (Dixon, Upper Rock, Brickyard, and Roxana) are presently or will be

significantly larger than the LMOP database indicates, either because they’ve pooled their gas with neighboring facilities, or because they’ve been permitted for large expansions, or because the LMOP database simply contains incorrect data.

• One (CDT) was required to capture its gas due to NMOC emissions. • Two (Streator Area and Brickyard) pursued carbon credits in association with

their projects, indicating that the projects are financially additional. The statistical evidence shows that only a minority subset of eligible landfills in the state of Illinois actually pursue gas to energy projects. Of those that do, most are larger than Clinton. Of those comparable in size, qualitative evidence suggests that extenuating circumstances are generally required to bring a project to fruition. We conclude that such projects are not yet common practice for landfills comparable to Clinton.

39 http://www.ilcswma.org/documents/pdf/newslettermar09.pdf 40 http://yosemite.epa.gov/r5/il_permt.nsf/

1187a64140e3f8ad862568b700763ce9/0669350ed3eba4cd85257482005b8230/$FILE/99090089.pdf

clinton landfill #2 gas collection and combustion clinton ... - clinton pdd v1.3... · clinton...

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