SUMMARY OF SMALL ENTITY OUTREACH. 2014

The EPA held meetings with municipal solid waste landfill small entity representatives. A summary of the

outreach conducted and written comments received appears below.

The EPA met with small entity representatives on October 30, 2013. The meeting was conducted as

follows.

10:00 Welcome and Introductions (EPA)

10:15 RFA/SBREFA Overview (EPA)

10:30 Background Presentation (EPA)

11:15 Discussion (All)

11:50 Summary and Closing (EPA)Summary of Written Comments from Potential Small Entity Representatives Submitted after the

October 30, 2013 Outreach Meeting

Topic Comment

Emission threshold  Lower threshold could cause site to incur significant cost

 May impact existing beneficial use projects that have benefitted from being

located at sites that are non

‐ NSPS and therefore eligible for additional

revenues

 Most smaller landfills do not generate sufficient gas for LFGTE projects

Treatment definition  Retain non

‐ numeric definition

 A LFGTE project will treat the gas to meet the requirement of the proposed

equipment in order to comply with the manufacturer’s warranty

 Numeric criteria would potentially require a modification/redesign of the

existing equipment

 Have to install continuous monitoring equipment to demonstrate these

criteria are met during operation

 Gas treatment system is not an emission point, but a physical process where

LFG is prepared for combustion in LFG fired generator sets

 Requirements for RICE MACT and spark ignition engines ensure appropriate

emission reductions

 Increases burden with no measurable improvement in emissions

Surface monitoring  Retain EPA method 21

 Does not appear to have a quantifiable environmental benefit

 SEM is time consuming

 Rules already require additional monitoring be performed at cracks in the

cover or in areas where vegetation is stressed

 Understand limitations on monitoring during high winds and precipitation,

but that should be coupled site

‐ specific alternatives

 SEM pattern should remain unchanged. Do not include integrated and

instantaneous measurements. All increase compliance burden.

 Is EPA considering changing the instantaneous compliance threshold of 500Topic Comment

ppm methane above background

 What thresholds are being considered for integrated measurements

Wellhead standards  Remove wellhead performance standards

 Eliminate or relax requirements for temperature and oxygen

Emission reductions  Share specific targets/goals for reductions and cost thresholds

Wellfield expansion  More well extensions and redrilling adds significant cost

 Tighter timeline compromises ability to meet wellhead requirements

 Prescriptive corrective action requirement is unnecessary

 Reduction of time allowed for expansion of the wellfield, particularly in

active areas, could result in operational difficulties

 It may be difficult to place a sufficient column of waste over a shorter time

period in the affected areas for installation of gas extraction wells

 During the first 2 years of waste placement, portions of the waste are likely

to be in the aerobic phase of LFG production

 Complying with NSPS operational standards may be difficult (specifically

oxygen or balance gas limitations)

 Gas collection from low producing areas will also cause a reduction in gas

quality, which will directly affect the ability to beneficially use LFG and

creates more potential for subsurface firesThe EPA met with small entity representatives on December 19, 2013. The meeting was conducted as

follows.

10:00 Welcome and Introductions

 Panel member introductions/remarks

 SER introductions

10:15 SER Presentations

10:45 Open Discussion (SERs and EPA)

This is an opportunity for SERs to provide comments to EPA on the following:

 Clarifications that are needed in the landfill rules

 Options and ideas that EPA should consider beyond those that were presented at

the October 30, 2013 Pre

‐ Panel Meeting

 Monitoring and recordkeeping: reactions to current requirements and

recommendations

 Technological advances that should be considered

 Availability of new models

 Additional issues

11:50 Summary and Closing (EPA)Summary of Written Comments from Small Entity Representatives Submitted after the December 19,

2013 Outreach Meeting

Topic Comments

Treatment Definition  Leave the definition as is. Facility meets definition as provided in

EPA guidance documents (compressed, chilled, dehydrated)

 Existing equipment would potentially have to be redesigned or

modified to meet numeric criteria

 Installing, maintaining, and operating continuous monitoring

equipment to demonstrate ability to meet treatment criteria

would increase compliance burden on landfills

 RICE MACT and NSPS for spark ignition engines already ensures

appropriate emission reductions

 Specifying numeric criteria will not affect the resulting emissions

engines, nor will it decrease NMOC

 Increases burden with no measurable improvement in emissions

 1996 NSPS rule does not include a definition of treatment

system. EPA proposed the following definition in the May 23,

2002 proposed amendments to the original 1996 rule:

Treatment system means a system that filters, de

‐ waters and

compresses landfill gas (67 FR 36480). EPA should adopt this

definition.

 In 2006 EPA proposed “treatment” standards to include

operating limits and monitoring. We believe that proposal is

inappropriate and unnecessary because:

‐ Treatment systems are not control devices,

‐ EPA’s proposal would not provide the operator of the

treatment system with any information that would

enable a reduction in emissions because neither the

filtration, compression, nor the dewatering process

produce emissions that could be reduced

‐ Regulating the operating limits and monitoring will

inhibit the development of LFGTE at small entity

facilities which are already challenged with numerous

technical and financial barriers due to their small LFG

flow. Adding more unnecessary regulatory and financial

burden to these projects is inappropriate.Topic Comments

 2006 proposal does not account for the site

‐ specific

characteristics that may impact operating requirements for each

LFG treatment system and control device

‐ Site

‐ specific preventative maintenance plan and a Start

‐

up, Shutdown and Malfunction Plan are sufficient and

prescriptive standards not warranted

‐ Regulating the treatment of LFG is simply not necessary

to ensure that LFG is properly combusted

 Any landfill gas that is collected and used for beneficial use

should be allowed without prescriptive requirement. The LFGTE

project will treat gas to the needed conditions to be used by the

proposed equipment

 Placing requirements on the treatment process will only create a

disincentive to do a LFGTE project

 The LFGTE project, not the treatment process, creates the real

environmental benefit. As such, the treatment definition should

not be changed

Wellhead requirements  Remove wellhead performance standards

 Requirements result in an overly burdensome compliance

exercise that does not result in NMOC reductions

 For wells installed in non

‐ producing areas, complying with the

wellhead standards can be difficult

 Waste naturally degrades at varying temperatures, some of

which occurs above the NSPS wellhead standard

 Landfill has several wells that naturally operate above 55°C

(131°F) with no indication of fire in the vicinity of the well

 Should be the responsibility of the landfill/gas system

owner/operator to ensure the system is

 operated to prevent a fire and not a requirement of NSPS

 Support the removal of the wellhead performance standards

from NSPS and the continued use of SEM to directly measure

emissions and demonstrate complianceTopic Comments

 Regulated community views the wellhead performance

standards as overly prescriptive with extremely complex

recordkeeping and reporting requirements and associated

corrective actions that vary widely due to divergent agency

interpretations

 Amount of data tracking and paperwork to demonstrate

conformance with wellhead standards is very burdensome and

can delay or distract the regulated community and state

agencies from accomplishing overarching goals of the NSPS

 Prescriptive wellhead standards are an obstacle to proper

system operation and emission reductions

 State agencies do not have resources to assess and respond to

landfill operator requests for operating variances, and due to

staff turnover, often lack knowledge and expertise

 Difficult to obtain higher operating variances and alternative

timelines from agencies, so operators adjust LFG flow to the

wells to meet specified temperature and oxygen values. This

lowers the efficiency of the system and can result in less gas

being extracted to fuel energy recovery projects or flares

 Unnecessary system expansions must be performed at great

expense with no environmental benefit

 Expanding the collection system would further propagate a fire

by introducing more oxygen into the landfill through drilling or

excavation activities

 Recommend the standards for oxygen and temperature be

eliminated

 Existing wellhead standards are not the best indicator of GCCS

performance because they are arbitrary limits on a limited

number of parameters which do not accurately represent proper

GCCS performance

 Existing wellhead operating standards do not reduce NMOC

emissions

 Landfill owners are already heavily incentivized to maximize

GCCS collection efficiency to control odor, control subsurface

migration, minimize groundwater impacts, maintain cap stability

and integrity, control surface emissions, and maximize energyTopic Comments

recovery

 Of the current wellhead operating standards, only pressure is

indirectly tied to controlling emissions

 Do not believe that the wellhead pressure standard provides

additional environmental protection

 Considering that the landfill cover soils have emission retention

qualities even gas pressure under the cap is not an indicator of

emissions

 Wellhead standards do not measure emissions

 Let the landfill owners operate their well field consistent with

their GCCS Design Plan such that surface emissions are

maintained below the standard

 Creating prescriptive treatment system standards along with

monitoring and recordkeeping requirements will add significant

barriers to energy recovery and fuel conversion projects and

could squash further development

 Very prescriptive standards are not warranted and create a very

complex and onerous set of monitoring and remediation

standards

 Standards are not needed and requirement to expand GCCS will

result in making operation of the GCCS worse and not better

 Unnecessary expansions are costly; typical cost to install one

well range from $12,000

‐ $15,000 which does not include drill

crew mobilization charges

 Current wellhead performance standards actually impede

and/or hinder a site from being able to maximize LFG collection

 If a site can meet SEM requirements, EPA should not dictate

what individual parameters need to be met at each wellhead for

pressure, oxygen, and temperature. Monitoring and remediation

of these parameters is a significant cost and creates an undue

level of complexity in data tracking and regulatory

correspondence that has no direct impact on reducing surface

emissions

Surface monitoring  Direct measurement of surface emissions is a better means to

assess the effectiveness of a gas system. This is similar to theTopic Comments

sentiment indicated by EPA in the background information

document (BID) for the final NSPS standards (EPA

‐ 453/R

‐ 94

‐ 021). The BID states “EPA considers surface emissions

monitoring to be an appropriate tool for monitoring both cover

integrity and the effectiveness of well spacing and vacuum in

order to ensure adequate collection efficiency”

.

 Current SEM requirements are appropriate and there does not

appear to be data to indicate the current SEM procedures are

inadequate

 Inclusion of enhanced SEM monitoring in a proposed rule

change would be an increased compliance burden on the landfill

 Does not appear to be data to indicate that expanded SEM

would result in a direct reduction in NMOC emissions

 Unless data can be provided to demonstrate enhanced SEM is

better and will reduce NMOC emissions, there does not appear

to be a valid reason to change the current SEM

requirements

 Primary focus of the rule should be to control emissions which

can be successfully accomplished utilizing the existing SEM,

which can evaluate the effectiveness of active and passive gas

collection systems and cover

 Focus of rule should be on controlling emissions. Can be

accomplished using the existing surface emissions monitoring,

which can evaluate effectiveness of active and passive gas

collection systems and cover

 Does not appear that there is adequate quantifiable

environmental benefit that can be determined from increasing

spacing on monitoring

 Rules already require that additional monitoring be performed

at cracks in the cover or in areas where vegetation is stressed

 Current requirement adequately locates surface emissions

through the cover

 SEM is a time

‐ consuming compliance activity

 Tighter grid spacing requirement should be based on some

demonstrable environmental benefitTopic Comments

‐ enhanced SEM nationwide, would be burdensome for

small facilities (significant increase in cost, new

equipment, and training of personnel)

 Current SEM method with NSPS is a very reliable method for

determining if a site is actually excess surface emissions and

does not rely on theoretical models

 Recommend NSPS be revised to include SEM as an additional

step in determining whether or not a GCCS needs to be installed

at a landfill. Additional step of adding SEM applicability criteria

would eliminate uncertainty associated with modeling and use

actual site specific conditions to determine the need for a GCCS.

If a site can show compliance with surface emission standards

without the benefit of GCCS; then it should not be required by

NSPS to install one

 There may be other possible methods, but there does not

appear to be any quantifiable results that suggest current

requirements are not adequate or that another method would

result in something better

 Adoption of a method only used in one part of the country does

not seem to be an appropriate reason to make a global change

to SEM, unless it was part of other proposed changes in the rule

that would be related to a more stringent SEM requirement (e.g.

removal of wellhead standards)

Methodology  EPA’s [1996 final rule] analysis noted the selected size threshold

exempted 90% of existing landfills, while missing only 15% of

total NMOC emission potential. Total emissions potential should

be much lower today given many of the small sites are closed

landfills

General  EPA GHG inventory indicates over 11% decline in methane

emissions from landfills since 1990

 No need to modify the rule for additional emission reductions

 Landfills have demonstrated that cover soils will oxidize organic

compounds

 With increased permitting requirements associated with

greenhouse gas permitting under the Tailoring Rule, it could

take over a year to get an air permit to install a control device or

longer if biogenic emissions are not exemptTopic Comments

Cost  Emission reductions to date have been at a reasonable cost

 Additional emission reductions can only be achieved through

very high costs

 Cost burden for installing a landfill gas system is significantly

greater for a small facility than a large one (e.g. significant cost

to incurred to simply mobilize a drill rig)

 Mobilization costs can be distributed over the cost of the wells

for a facility that installs many wells

 Individual well cost higher for smaller facilities with fewer wells

 Cost will be high for smaller landfills (e.g. design, permitting and

construction, monitoring and operations

 Request no changes to the NSPS thresholds because there does

not appear to be enough justification for lowering emissions.

GCCS impose a substantial cost to landfills and there is a desire

not to increase disposal rates to its citizens

 Requiring systems and components to be installed earlier will

greatly increase cost of operating and maintaining the system

 Placing GCCS components within the active working areas of the

landfill is already an issue but requiring them to be installed

even earlier will result in more well extensions and redrilling,

which adds significant cost

Emission threshold  Consider allowing use of surface emissions monitoring to

confirm whether modeled excess emissions actually exist

 Adding a SEM applicability criterion to the NMOC threshold

criteria will assure gas systems are installed and/or expanded at

the appropriate time to maximize emissions reductions

‐ would require many additional landfills to comply and

the cost to comply versus the emission reductions would

be unreasonable at approximately $14,000 / metric ton

NMOC reduction

 Lowering the emission threshold could require site to install and

operate landfill gas collection and control system in the next

couple of years at a significant cost. Initial GCCS costs about

$2million. Monitoring, recordkeeping, and reporting costs under

the current NSPS are estimated to be $50,000/year.Topic Comments

 Proposed lowering of emission threshold is based on modeled

emissions of NMOC and not actual emissions, including model

variables that are not site

‐ specific

 Does not seem to be any technical or scientific justification for a

downward adjustment to the emission s threshold

 Any downward adjustment would have a significant impact on

the operations and costs from smaller landfill owners

 No new technology has been developed since the

implementation of the current NSPS that would warrant or

justify changing the current emission threshold

 Current emission threshold appropriately identifies those

landfills that may need to have controls installed

 Current emissions threshold (based on modeling) coupled with

actual SEM data, would be recommended before a GCCS is

required to be installed

Installation timeframe  Ability for regulated community to comply with shortened

installation timeframe is jeopardized

 Compressed schedule is a burden on construction and operation

activities

 Requires installing LFG collection system during active

operations which subjects collection system to damage from

operations

 Increased sediments in the landfill affects landfill gas header

alignment. Results in more operational troubleshooting, repairs,

and replacement costs

 Earlier operation will lead to significantly greater numbers of [

well] exceedances requiring greater number of system

expansions which adds to the cost burden of earlier collection

‐ Considering the rules of procurement for municipalities

it will be difficult to reduce this time

‐ Approval period has been very long in most States and

some States have never approved a submitted design,

making it very cumbersome for the landfill owner to go

to bid for constructionTopic Comments

‐ Shortening the time allotted for installation of the GCCS

would create added burden on small entities and should

not be pursued

 Shortening of time would be burdensome, if not impossible

 Process of getting designs, permits, city council approvals, plus

the time needed for advertisement, bidding, and construction,

would be difficult under the current timeframes.

 Given the time needed to properly design, permit, bid, and

construct a project, the shortening of timeframes for any site,

especially a municipality, would create hardship

 Having to install components at a site early will greatly increase

the cost of operating and maintaining the system and the need

to have those components replaced in the future

Owner/operator issues  Common control establishes a disincentive for landfill gas to

energy projects

 Being held responsible for actions or inactions of an

independent contractor is untenable

 Permits should allow clear division of responsibilities between

landfill owner and the owner of the LFGTE facility

 Does not want to be held responsible for actions and/or the

equipment of independent 3 rd party entities

 If responsible for actions of independent 3 rd parties through rule

revisions, likelihood of pursuing a landfill gas to energy project is

very low

 Not willing to allow equipment not owned and personnel not

controlled to potentially put city in a noncompliance situation

 Change in rules would hurt the potential for a LFGTE project,

which could otherwise be very viable, create jobs, and reduce

emissions

 Support allowing a division of liabilities to be established

between parties which could be provided to the regulating

entity

Closed landfills  Additional relief from performance and monitoring should be

granted to closed landfills (e.g. landfill may not have sufficientTopic Comments

LFG to maintain and operate a LFG collection system for 15

years, meet the 5% oxygen wellhead standard, and perform

system expansion)

 Much of the LFG emissions might have oxidized through cover

soils resulting in minimal pollution

 Consideration should be available for oxidation of the LFG

Decommissioning Wells  Rule should be revised to allow for decommissioning of portions

of the LFG system

 Make provisions for both temporary and permanent

decommissioning based on site specific conditions

Landfill lifecycle  Rule does not adequately address the lifecycle of a landfill,

including phasing

‐ in gas collection systems for newer landfills or

newly developed areas of landfills, or tapering down collection

systems for older landfills where gas production is diminished

 Compliance with wellhead performance standards is difficult at

the beginning or end of the landfill’s life

 Sites need operational flexibility to rely on interim collection in

the early generation years and intermittent system operations in

the low gas producing years

 Rule does not address ramping up the gas collection and control

system (GCCS) for new landfills or tapering down the GCCS for

old landfills

Cost analysis  Cost shown in spreadsheet seem low, especially considering that

the facilities that would be impacted are significantly smaller

and would not enjoy the same economies of scale

 Cost assumptions assumed many of the facilities would benefit

from beneficial use and that rationale does not seem to consider

the size of the facilities

 Closed landfills are unlikely to provide gas for a period long

enough to see a return on investment

 Many smaller landfills do not generate sufficient gas to enjoy the

opportunity to install beneficial use options.

 Cost benefits to small facilities are minimalTopic Comments

 Small landfill adjacent to an industrial user may see benefits but

this situation is rare

 Cost will be significantly larger than EPA estimates

 Cost benefit would need to be clearly defined before suggesting

changes that would increase or expand the scope of SEM

 EPA’s [final rule] cost benefit analysis ($/ton NMOC reduced)

that supported the 2.5 million Mg and 2.5 million cubic meter

design capacity remain relevant today

‐ EPA’s [final rule] cost benefit analysis ($/ton NMOC

reduced) that supported the 50 Mg/yr threshold

remains relevant today

‐ Options that propose early installation of wells needs to

include costs for additional repairs and needed

replacements. Vertical well installed in an area that will

receive additional waste will need to be extended and

eventually replaced

 Extension and replacement costs will greatly increase for options

that require earlier installations. As a general rule, each 5ft well

extension costs about $400

, and once a well has been extended

4 times (20 ft), the well will need to be replaces

 Horizontal collectors will fail sooner and require replacement

since more lifts of refuse will be placed over them after

installation

 Cost for bringing needed power service to the site need to be

included in cost calculations (for options that lower the

applicability threshold and require new sites to install a GCCS)

 Cost of electrical service (to provide sufficient power to run

blowers) is site specific, but recent experience shows costs can

be as high as $500K

 Benefit of a LFGTE project is very site specific. Changes in energy

markets, tax laws, and regulations mean some LFGTE projects

make little to no money

 In many cases it is currently more economical to flare gas than

to install and operate a LFGTE project (as such it would seem

appropriate to apply a reduction in compliance costs)Topic Comments

 Assumption that a site could have a LFGTE project and that it

could generate enough revenue to offset compliance costs

cannot be applied across all sites

 As a small entity, the economies of scale may not allow the costs

to be viable, but the cost of compliance would still be incurred

 Some of the NSPS options would increase costs and thus reduce

the viability of being able to do a LFGTE project at smaller sites

Size threshold  Lowering NSPS thresholds may also impact beneficial use

projects that have benefitted from being located at sites that are

non

‐ NSPS and therefore eligible for additional revenues

‐ lowering threshold would require many additional

landfills to comply and the cost to comply versus the

emission reductions would be unreasonable at

approximately $18,000 / metric ton NMOC reduction

 Landfills with a design capacity of less than 2.5 million Mg and

2.5 million cubic meters is very small by today’s standards and

most likely would not be able to support the additional burden

placed on it by more stringent NSPS requirements

 Smaller landfills have less gas generation, less opportunity for

gas

‐ to

‐ energy projects, and fewer emissions

 No new technology has been developed that would warrant or

justify a change in the size threshold

 Current size threshold appropriately identifies those landfills

that need to be further evaluated for potential controls

Fires  If minimizing the risk of a fire is truly the concern for the EPA,

the requirement for system expansion in many circumstances

would further propagate the fire by introducing more oxygen

into the system through drilling or excavation activities.

 If EPA remains concerned about potential fire risks, it is

recommended that the facility include prevention and mitigation

practices in the GCCS Design Plan, sealed by a professional

engineer

 40 CFR 258.21 already requires controls to reduce landfill fires

namely: “Cover material requirementsTopic Comments

Failed tier 2 test option  If an owner fails a tier II test (i.e.: the calculated NMOC

emissions are greater than 50Mg/year) then they must conduct

tier III testing or install/operate an active LFG collection system;

recommend another option be allowed, namely, an SEM

demonstration

 SEM demonstration would be performed using current NSPS

procedures and if methane emissions were found or repaired to

be lower than 500 ppm below background, then installation of a

GCCS could be delayed

 Believe numerous GCCS have been installed and operated at

great expense that are not justified because they reduce very

few emissions that a good soil cover could achieve at much

lower capital and operating costs

Passive flares  Use of passive flare devices may allow reductions of NMOCs in

remote areas such as landfill cleanouts to the leachate collection

system and low methane producing areas

 Under current NSPS rules this installation is not possible because

the NSPS requires open flares to meet 60.18 and have

continuous flow recorders and flare pilot flame monitoring

 Equipment is not cost effectively available at remote locations

such as the leachate cleanout devices

 If EPA wants to promote destruction of more NMOCs then EPA

will need to waive the requirements for flow measurement and

pilot flame monitor in remote areas and low methane producing

areas

Wellfield expansion  Waste is typically not to final grade for at least 7 years at most

landfills so the 2 year rule is rarely applicable at today’s modern

landfill

 Most landfill owners / LFG operators in wet climates are

installing temporary LFG collectors before the 5 year rule is

invoked, partially in an effort to comply with NSPS/EG but also

partially to maintain control of odors or to capture energy

 Early installation is not typically occurring in dry climates

 Early GCCS installations almost never comply with the wellhead

standards but they don’t have to comply until the 5 year clock is

triggeredTopic Comments

 Since landfill owners / LFG operators in wet climates already

typically install the GCCS before 5 years if the EPA changes the

rule to less than 5 years it would result in no less emission

reductions than the current rule already provides

 Lowering the 5 year rule would create more administrative

burden for LFG collectors that can’t meet the existing NSPS/EG

wellhead standards, would not lower emissions, and would

create undue expense on the landfill owners / LFG operators

 Do not recommend any change to the 2yr/5yr rule

 Gas system expansion every couple of years would cost

approximately $250,000 for each event. Additional costs would

be incurred to operate associated blowers. Cost would likely

lead to an increase in disposal rates for citizens served by the

landfill

 Shortening of time would be burdensome if not impossible

New technology  Landfill industry has not developed new control technologies

since the original implementation of NSPS

 Best demonstrated technology remains flares

 Barriers identified in the 1996 rulemaking to control

technologies other than flaring still exist today

 Important that any rule revisions seek to remove and not add

barriers to technologies such as energy recovery and fuel

conversion

 Industry has made improvements to wellhead and collector

designs, and improved data collection and tracking. Because the

NSPS/EG rule is so prescriptive, it is difficult to develop new

technology

Emissions modeling  Landfill industry is beginning to invest in research that will

ultimately improve our ability to predict LFG generation and

collection rates more accurately

 Widely thought that the methane generation rate (k) varies over

time, lowering when the landfill cap is installed and stormwater

is cutoff

 Widely thought in our industry that NMOC, VOC, Siloxane, H2S,Topic Comments

and other compounds typically found in landfill gas have varying

emission factors over time, lowering as waste decomposition

progresses

 More funding is needed to advance the state of practice in this

regard and better understand what the “real” emissions from

landfills are

 Solid waste industry is working hard to develop more accurate

methods to estimate actual emissions; but there is not currently

a sufficiently accurate method to determine actual emissions for

compliance purposes

 LandGEM overestimates emissions

 Current gas generation model can overestimate emissions by up

to 400%

 Recommend EPA incorporate methane oxidation into emission

calculation methodology for estimating landfill emissions

15 yr GCCS requirement  Recommend changes to address how a site/ area is able to

remove or be excluded from GCCS operations

 Recommend criteria be included in the rule to allow a site to

cease NSPS operation and control requirements based on NMOC

emissions and/or SEM compliance (regardless of how long the

GCCS has been online)

 For example, a site that can demonstrate that it does not have

surface emission exceedances and/or is below 50 Mg/yr

threshold of NMOCs should be allowed to cease GCCS

operations under the NSPS requirements

1% exclusion  Landfills should be able to decommission collection in non

‐ producing areas based on SEM results and not modeling

 If a percentage of NMOC s continues to be used in the rule, the

percentage should be increased from 1%, which has shown to be

an unattainable standard for almost all sites