1



### ENVIRONMENTAL PROTECTION AGENCY 1

2

3

4

5

6



### 40 CFR PART 60 7



### PUBLIC HEARING: STANDARDS FOR PERFORMANCE FOR 8



### MUNICIPAL SOLID WASTE LANDFILLS 9

10

11



### 9:05 a.m. to 5:57 p.m. 12



### Tuesday, August 12, 2014 13

14


### William Jefferson Clinton East Building 15



### 1201 Constitution Avenue NW 16



### Room 1 153 17


### Washington, DC 20004 18

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### EPA Panel Members: 1


### David Cozzie, Senior Program Advisor 2


### Hillary Ward, 3


### Environmental Protection Specialist 4


### Shaun Ragnauth (morning session), Economist 5


### Swarupa Ganguli (afternoon session), 6



### Environmental Protection Specialist 7

8



### WITNESSES: PAGE 9



### John Skinner 7 10



### Karimah Schoenhut 14 11



### Anne Germain 22 12

13

14

15

16

17

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### P R O C E E D I N G S 1


### MR. COZZIE: Good morning, my name is 2


### David Cozzie, and I am the chair of today's 3


### public hearing. Thank you for coming today. 4


### Joining me on the panel are Ms. Hillary Ward from 5



### EPA's Office of Air and Radiation, and Mr. Shaun 6


### Ragnauth also from EPA's Office of Air and 7


### Radiation. We are here today to listen to your 8


### comments on EPA's proposed updates to its new 9



### sourc e performance standards for municipal solid 10



### waste landfills. 11


### EPA announced the proposed updates, which 12



### would reduce emissions of methane

- rich landfill 13


### gas from landfills constructed, modified, or 14



### reconstructed in the future, on June 30, 2014. 15



### The prop osed updates would require new MSW 16


### landfills subject to the rule to begin 17


### controlling landfill gas emissions at a lower 18


### threshold than currently is required for new 19


### landfills. Under the proposal, landfills would 20



### capture two

- thirds of their methane and air 21


### toxics emissions by 2023. Thirteen percent more 22

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### than they must capture under current regulations. 1



### Methane and air toxics are linked to a number of 2


### harmful pollutant effects on public health and 3



### climate. 4


### The updates would apply to MSW landfills 5



### that begin construction modification or 6


### reconstruction on or after July 17th, 2014, the 7


### day which this proposal was published in the 8


### Federal Register. They would not apply to 9


### landfills subject to the current NSPS, which was 10


### issued in 1996. If you would like m ore details 11


### on the proposed updates, there is a fact sheet 12


### available near the registration desk. 13


### Before we get started, I would like to go 14


### through a few housekeeping items and ground rules 15


### that will help make today’s hearing runs 16


### smoothly. First, plea se be sure that you’ve 17


### checked in at the registration desk. Even if you 18


### are not planning speak today. And if you signed 19


### to speak online or by phone but haven’t told us 20



### that you are here, please step out to the 21


### registration desk and let the EPA staff know that 22

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### you have arrived. 1


### I will call speakers up individually. 2


### When your name is called, please come to the 3


### podium at the front of the room. When I call on 4


### you to speak, please state your name and spell it 5


### for the court reporter. Your comments will b e 6



### transcribed and included in the record of 7


### comments on the proposed rule. Each speaker will 8


### have five minutes to give comments. We have a 9


### light to let you know how much time you have left 10


### to speak. When the light turns from green to 11



### yellow, that means y ou have one minute remaining. 12


### When it turns red, that’s a signal that you are 13


### at five minutes and it’s time to stop. When you 14


### are finished speaking, pleas return to your seat. 15


### We are here to listen to you today, 16



### however, a panel member may ask you ques tions to 17


### clarify your comments. I will then call up the 18



### next speaker and so on. If you have brought a 19



### copy

-- a written copy of your testimony, please 20


### give that to staff at the registration desk 21


### before you leave today. If you have additional 22

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### comments th at you would like to make, you can 1


### submit them in writing. Let me assure you that 2


### EPA gives just as much consideration to comments 3


### we receive in writing as we do comments we 4


### receive at public hearings like this one. So, if 5


### you have more that you would li ke to say, please 6



### submit it. Your comments will be reviewed. And 7


### there is still time to get written comments in. 8


### Comments must be received by September 15th, 9



### 2014. 10


### We will put any written comments 11


### submitted today in the official docket for the 12



### propose d rule. Instructions for submitting your 13


### comments in other ways are in the fact sheet, 14



### which is available at the material near the 15


### registration desk. 16


### If you have any questions during the day, 17


### please see the staff at the registration desk, 18



### and someone w ill try to help you. Thank you 19


### again for taking the time today to share your 20


### comments on EPA’s proposal, and at this time we 21



### can get started. 22

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### And the first speaker I will call is Mr. John 1



### Skinner. 2


### MR. SKINNER: Good morning. I have a 3



### written statem ent, would you like copies? I’m 4


### not going to read it, but I will paraphrase it. 5


### MR. COZZIE: Yeah, if you have a written 6


### comment, if you would please leave it at the 7


### registration desk, that would be fantastic. 8



### MR. SKINNER: Do you want one now? 9



### MR. COZZIE: No. We will collect it at 10


### the registration desk. 11


### MR. SKINNER: Okay, fine, thank you. 12



### Shall I start? 13


### MR. COZZIE: You can go right ahead. 14


### MR. SKINNER: Thank you, good morning, my 15



### name is John Skinner. I am the executive 16



### director and CEO of SWANA, the Solid Waste 17



### Association of North America. We are not a trade 18


### association, we are a professional and an 19



### education association with 8,300 members in North 20



### America, the United States and Canada, and our 21


### members work both for the private sector and for 22

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### the public sector. About 60 percent work for the 1


### public sector and the remainder work for the 2


### private sector and they are active in landfilling 3


### across North America. We provide education and 4


### training for our members. 5



### The standards that you hav e put out and 6


### proposed is of very significant interest to all 7



### of our members, many of them who have been 8


### operating under the prior subpart WWW for many, 9


### many years. We noticed in the preamble that 10


### there are many, many questions that you ask, if 11



### you count them all, there are probably over 80, 12


### maybe even more if you look at the subparts of 13


### the questions, and there’s also many documents 14


### that you reference in the preamble. We believe 15


### that 60 days public comment is not sufficient to 16



### review all that material an d to comment during 17


### the comment period. Adding the fact that you 18


### also put out an advanced notice for emission 19


### guidelines that has a similar number of questions 20


### and documents putting them both together in a 60 21


### day public comment period is just not feasible

. 22

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### So we have requested formally, an extension of 1


### the comment period of both for an additional 60 2



### days. 3


### The landfills that have been operating 4


### under the existing subpart WWW have shown 5


### remarkable progress in reducing greenhouse gases. 6



### As EPA indicates , the amount of methane reduced 7



### from 1990 to 2012 has been over 30 percent by 8



### those standards, and that’s at a time when waste 9


### generation and waste disposed of in landfills 10


### increased by 26 percent so that’s also very, very 11


### significant

-- a very effective r egulation which 12


### the solid waste industry has complied with and 13


### achieved very, very considerably. 14


### A couple of specific comments on key 15


### provisions, and we will submit in detail, by the 16


### end of the comment period, a lot more comments 17



### and more details on this . The reduction of the 18


### emissions threshold from 50 milligrams to 40 19


### milligrams of NMOC is not unreasonable of a 20



### standard for new facilities. Our concern is when 21


### existing facilities modify their permit and 22

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### increase their capacity, they would be subject to 1



### these new standards as well, and we are

-- our 2


### question is, all of these facilities are 3


### currently operating under the WWW, would they 4


### then have to operate under the new provisions of 5



### subpart XXX, and that

-- if so, if that is the 6


### answer, the scope of this regulation is far 7


### greater than the proposal indicates. The 8


### proposal discusses the impact of new facilities, 9


### the impact on existing facilities could be very, 10


### very significant in terms of number of facilities 11


### and also very significant with respect to what 12



### those facilities have to achieve. So we would 13



### like clarification on that. 14


### A second issue that’s important to us is 15



### the proposed rule on startup, shutdown, and 16


### malfunction, where the standard would apply 17


### during that period. We feel that is an 18



### infeasi ble standard to comply with. Any thermal 19


### device has to come up to temperature before it is 20


### effective. Any mechanical or thermal device will 21


### have a malfunction, and to require that the 22

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### standard be met during that period of time, is 1


### just very unreasonable. Every facility will be 2


### out of compliance when they start up their 3



### thermal combustion device. And we think the 4


### existing rule under WWW, which allowed for some 5


### period of time to come into compliance, both 6


### during the startup and shutdown, and also during 7



### t he malfunction, is much more reasonable and we 8


### suggest that you please revisit that. 9


### We support the language that clarifies 10


### that the use of treated landfill gas is not 11


### limited to fuel for stationary combustion devices 12



### but also includes vehicle fuels and high BTU 13


### pipeline injection. We don’t believe it is 14



### necessary to set treatment standards for those 15


### gasses that are going to be treated. We think 16


### you should just simply refer to the 17



### manufacturer’s standards for those devices. This 18


### would have no impact o n emission rates, it would 19


### simply

– - those standards are there to protect 20


### the equipment, and rather than being prescriptive 21



### about that in the standard, we feel that it is 22

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### inappropriate. 1


### Finally, we also are concerned about a 2


### clear path from exiting the r egulatory 3


### requirements, once a site no longer exceeds the 4



### NMOC threshold. 5



### We will submit comments on all these 6


### points during the public comment period. Thank 7



### you. 8


### MR. COZZIE: Thank you Mr. Skinner. 9


### Panel, do you have any questions? 10



### MS. WARD: N ot at this time. Thank you. 11


### MR. COZZIE: And I just have one 12


### question. 13


### When you’ve referred to the modification 14


### of the permit, were you talking about permits 15


### that were modified prior to this date, or several 16



### of the

-- modified subsequent

-- 17



### MR. SKI NNER: After the date. Landfills 18


### go through permit modification all of the time, 19


### and many times those modifications increase the 20


### design capacity of the facility. In some cases, 21



### this

-- it is built into the permit review 22

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### process. Our reading is, that wou ld 1


### automatically subject those facilities to the new 2


### standards in subpart triple X, where many of 3


### those facilities are operating at triple W at 4


### this point in time. But I am talking about 5


### subsequent increases in permitting. 6


### MR. COZZIE: Okay. In relatio n to the 7


### startup shutdown malfunction, you mentioned

-- in 8


### your comments, will you submit some information 9


### or data talking about the startup time it takes 10


### to come up to temperature. Will that be included 11



### as well? 12



### MR. SKINNER: Yes, and we think the 13



### curr ent standard in WWW is appropriate. One day 14



### five

-- one hour five days is the type of de 15


### minimis period for both startup shutdown and 16


### modification, which would be something that we’ve 17


### complied with all of this time and would be able 18


### to comply with in the future. But a zero 19


### tolerance during that period of time is just not 20


### practical. 21



### MR. COZZIE: Thank you very much. 22

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### MR. SKINNER: Okay. 1


### MR. COZZIE: At this point in time, I 2



### would like to call forward Karimah Schoenhut. 3


### MS. SCHOENHUT: Good morning, my name is 4


### Karimah Schoenhut. I’m a legal fellow with the 5


### climate and air regulatory and policy program at 6



### the Environmental Defense Fund. 7


### EDF is a nonprofit, nonpartisan 8


### organization that combines law, policy, science, 9



### and economics to find solution s to today’s most 10


### pressing threats to public health and the 11



### environment. On behalf of EDF and its over 12


### 750,000 members nationwide, I urge EPA to 13



### strengthen the proposed new source performance 14


### standards for municipal solid waste landfills, 15



### and to adopt str onger protections for emissions 16


### from existing landfills. 17


### EPA’s current proposal fails to secure 18


### vital and highly cost

- effective emission 19


### reductions for methane, a potent accelerant of 20


### climate destabilization, and does not adequately 21



### account for the mos t recent science thoroughly 22

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### documenting the dangerous force of this climate 1



### change accelerant. 2


### Landfills are the nation’s third largest 3


### anthropogenic source of methane, which is 4


### generated along with air toxics and ozone forming 5



### pollutants as the waste deposited in landfills 6



### decomposes. 7


### Methane is a powerful climate pollutant 8


### that is 84 to 86 times more potent than carbon 9



### dioxide within the first two decades after it is 10


### emitted, and 28 to 34 times more potent even a 11


### century after its emission. Studi es show that 12


### reducing methane now from major source sectors, 13


### such as oil and gas development and municipal 14


### landfills, while simultaneously making deep cuts 15


### in carbon pollution from other major sources like 16


### power plants, is crucial for slowing the rate of 17



### n ear

- term climate change and securing long

- term 18


### climate stability. 19


### This proposed rule is an important part 20


### of the White House strategy to reduce methane 21


### emissions, and is also required by the Clean Air 22

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### Act, which directs EPA to review, and if 1


### appropriate, revise the NSPS for each category at 2


### least once every eight years. EPA’s current NSPS 3


### for landfills has not been updated since 1996 and 4


### no longer reflects the full range of technologies 5



### to reduce emissions from landfills. 6


### Just in the last two years, for example, 7


### the state of California extensively analyzed the 8


### latest technologies and practices for reducing 9


### landfill emissions. California adopted well

10


### designed modern standards that protect human 11


### health and the environment beyond the NSPS by 12


### covering a large number of landfills, ensuring 13


### rapid installation and expansion of emission 14


### controls, and requiring rigorous monitoring to 15


### ensure landfills prevent leaks of methane and 16



### other harmful pollutants to the atmosphere. 17



### EPA action to modernize standards for both new 18


### and existing landfills is urgently needed and 19



### long overdue. The proposed rule does represent 20


### some limited progress. The proposed NSPS would 21


### modestly reduce the emission threshold that 22

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### ensure landfills install basic emission controls, 1



### and it woul d require monitoring of certain 2


### landfill features where leaks frequently occur. 3



### EPA estimates these measures would reduce 4


### emissions from new landfills by approximately 13 5


### percent in 2023, the equivalent to just over 6



### 300,000 metric tons of carbon dioxide using EPA’s 7


### current global warming potential for methane, and 8


### at a very low cost, just a dollar fifty for every 9



### ton of CO 2 

### equivalent emissions reduced. 10


### Nevertheless, the proposed rule misses 11


### opportunities to set standards that truly reflect 12



### state

- of

- th e

- art technologies and best practices 13


### in this industry, as section 111 of the Clean Air 14


### Act requires. For example, EPA proposes to 15


### continue allowing landfills up to five years to 16


### install a gas collection system, even though 17


### leading researchers have conclu ded that almost 30 18


### percent of total emissions from a landfill are 19



### emitted within this timeframe. EPA’s own 20


### analysis shows that earlier gas collection would 21


### yield significant additional reductions of almost 22

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### 1,000,000 metric tons of CO 2 

### equivalent in 2023. 1


### In addition, the proposed rule does not 2


### require rigorous monitoring to ensure that 3


### landfills are properly maintained and operated. 4


### The current NSPS requires only a small portion of 5



### the landfill surface to be monitored each 6


### quarter, potentially allowing many leaks to go 7


### undetected and unrepaired. California requires 8


### approximately four times as much monitoring as 9


### the current NSPS and provides for a rigorous 10


### average limit on methane emissions in addition to 11


### a limit on individual detection readings. We 12



### urg e EPA to strengthen NSPS in these and other 13



### respects. 14



### In parallel, EPA must also take prompt 15


### action to reduce emissions from existing 16


### landfills. Existing landfills will emit far more 17



### methane and other harmful pollutants than new 18



### landfills for the fore seeable future, and present 19


### opportunities for significant and cost

- effective 20


### reductions in emissions. EPA’s analysis 21


### indicates that reduced applicability threshold 22

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### and early gas collection at existing landfills 1


### could avoid approximately 770,000 metric ton s of 2


### methane emissions a year at a cost of only four 3



### twenty

-- four dollars 20 per ton of CO 2 4


### emissions. Using the IPCC’s more accurate 20

- 5


### year value for methane global warming potential, 6


### these reductions are equivalent to approximately 7



### 65,000,000 metric tons of CO 2 

### each year. 8


### Strong standards for existing landfills would 9


### leverage the innovative technologies and 10


### practices that many communities and landfill 11


### operators around the country have implemented 12


### already to reduce emissions including, recycling 13



### and co mposting, responsible use of landfill gas 14



### for energy and advance cover systems. 15


### Thank you for this opportunity to share 16


### our thinking on these issues. We look forward to 17


### providing more detailed submissions before the 18


### end of the public comment period. 19



### M R. COZZIE: Thank you, Ms. Schoenhut. 20


### Panel members, any questions? 21


### MS. WARD: I had a couple questions. 22

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### You mentioned that in the proposal, rigorous 1


### monitoring was not required and you referenced 2


### the California approach. Have you explored 3


### anything b eyond that, or were you specifically 4


### advocating for the adoption of the California 5



### approach? 6



### MS. SHOENHUT: I think that EDF would 7



### like to consider

– would like EPA to consider the 8


### California approach as an example, as perhaps the 9


### best example of rigorou s monitoring, but we will 10


### provide more detailed comments on that in our 11



### written comments. 12



### MS. WARD: And the same as a follow

- up 13


### question toward expansion, you mentioned the five 14


### year timeline that’s allotted for expansion of 15



### the well system and how that does not, in your 16


### opinion, necessarily accurately account for gas 17



### that comes off the landfill. 18


### Were you advocating for a tightening of 19


### that time, or a removal of that time, or were you 20


### thinking to explore that more in your comments? 21


### I just wanted to get a little clarification 22

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### there. 1


### MS. SCHOENHUT: For a tightening of that 2


### time period. And that will be addressed

-- the 3


### extent of the tightening will be addressed in the 4



### written comments. 5



### MR. RAGNAUTH: No comments. 6



### MS. SCHOENHUT: Thank you. 7



### MR . COZZIE: Thank you very much. 8


### Well I believe that’s the extent of our speakers 9


### that have signed up, to this point. So, given 10


### that, I will put the hearing into recess until 11



### any other speakers show up. 12



### Thank you. 13



### [WHEREUPON, A RECESS WAS TAKEN AT 9 :24 14



### AM. THE HEARING RECOMMENCED AT 10:30 AM] 15


### MR. COZZIE: Good morning, the time now 16


### is 10:30 am and I am reconvening the panel on the 17


### public hearing on proposed updates on new source 18


### performance standards for solid waste landfills. 19



### At this time I will call forward Anne Germain. 20


### MS. GERMAIN: So, just go ahead? 21


### MR. COZZIE: Go right ahead. 22

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### MS. GERMAIN: Okay. Good morning, I am 1


### Anne Germain, director of waste and recycling 2


### technology, for the National Waste and Recycling 3


### Association. Thank you for the opportunity to 4


### testify on the agency’s proposed rule for 5


### standards of performance from municipal solid 6



### waste landfills. The National Waste and 7


### Recycling Association, formerly the National 8



### Solid Waste Association, is a not

- for

- profit 9



### trade associa tion representing private solid 10


### waste and recycling collection processing and 11


### management companies. Our members own and 12


### operate the majority of the landfills in the 13



### Unites States. 14


### When these rules were first promulgated 15


### in 1996, our members responded by investing 16


### significant capital and human resources in 17


### installing, expanding and improving their 18


### landfill gas collection and control systems, as 19


### well as their landfill cover systems. These 20


### efforts have resulted in significantly reduced 21



### emissions. 22

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### As highlighted in EPA’s Inventory of U.S. 1



### Greenhouse Gas Emissions and Sinks, between 1990 2



### and 2012, landfills have reduced methane 3


### emissions by more than 30 percent. The 1996 NSPS 4


### emission guidelines have been very successful in 5


### prompting development by the landfill sector of 6


### highly effective methane controls. As the EPA 7


### moves into new amendments to these regulations, 8


### it is important that proposals build on successes 9


### that the industry has worked so hard to achieve 10



### over the past 18 years. 11



### We believe that t he EPA should streamline 12



### the standards to eliminate the historical 13


### bureaucracy that has hampered effective 14


### implementation of methane controls, and avoid 15


### establishing new provisions that are neither 16



### cost

- effective, nor achieve new methane 17



### reductions. EPA s hould recognize that many 18


### landfills are partially or fully closed and these 19


### sites need flexibility to adjust their control 20


### systems to compensate from diminished methane 21


### generation and appropriately exit the regulatory 22

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### regime. The current regulations do no t 1


### effectively provide that needed flexibility. 2


### In our initial review of the prosed rule and 3


### accompanying technical analyses, we noted that 4



### the agency was hard

- pressed to identify 5



### additional means to obtain further cost

- effective 6



### methane reductions. While the intent of this 7


### rulemaking is to further reduce emissions, our 8



### members are concerned that many of the proposed 9


### measures will do little to achieve that goal. 10


### The proposed revisions make it more difficult for 11


### landfills to optimize the performance of thei r 12


### landfill gas collection and control systems by 13


### perpetuating prescriptive standards that require 14


### them to make system adjustments that often hamper 15


### emissions controls. Rather than reducing 16


### needless bureaucracy, these provisions actually 17


### increase paperwork and administrative burdens for 18



### both the landfill sector and our state 19


### regulators, with no attendant environmental 20



### benefits. 21


### The U.S. landfill sector has successfully 22

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- 752

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- 445

- 337625



### pioneered the use of landfill gas to produce 1


### renewable electricity and facility and 2



### tra nsportation fuels. There are over 600 3


### renewable energy projects in the United States in 4


### part, through the cooperative efforts of landfill 5


### owners and operators as well as EPA’s Landfill 6


### Methane Outreach Program. However, EPA is 7


### proposing new landfill gas treatment requirements 8


### that are superfluous to the operation of these 9


### beneficial projects, resulting in zero emissions 10


### reductions and significantly increasing project 11



### costs. We are very concerned that the proposed 12


### provisions will discourage the developmen t of new 13


### renewable energy projects and may force existing 14


### projects to shut down. 15


### The industry is beginning a detailed 16


### review of the rule and supporting documents. In 17


### addition to publication of the proposed NSPS, the 18


### solid waste industry must also respon d to the 19


### advanced notice of proposed rulemaking for 20


### Emission Guidelines and Compliance Times for 21


### Municipal Solid Waste Landfills that was issued 22

OLENDER REPORTING, INC. 1100 Connecticut Avenue, NW, #810, Washington, DC 20036

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### that same day. Both proposals entail review of 1


### hundreds of pages of technical documents and 2


### preparation of inf ormation and comments to 3


### numerous Agency questions that will require 4


### extensive time and resources, particularly within 5



### that same 60

- day period. As such, we have 6



### requested a 60

- day extension be provided to 7



### commenters on the proposed NSPS so that the EPA 8



### wi ll benefit from a thoroughly researched 9



### response. 10


### In closing, the National Waste and 11


### Recycling Association appreciates your 12


### consideration of our testimony today and 13


### forthcoming recommendations on these standards of 14



### performance. Should you have any quest ions about 15



### these comments, please feel free to reach me at 16



### (202) 364

- 3724, or at amgermain

-- sorry, at 17


### agermain@wasterecyling.org. 18


### On behalf of the solid waste recycling 19


### industry, thank you for your thoughtful 20



### consideration of these comments. 21



### MR. COZ ZIE: Thank you, Ms. Germain. 22

OLENDER REPORTING, INC. 1100 Connecticut Avenue, NW, #810, Washington, DC 20036

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### Panel, any questions? 1


### MR. RAGNAUTH: I have no questions. 2



### MS. WARD: Hi, Anne. 3



### MS. GERMAIN: Hello. 4


### MS. WARD: Do you know if you guys will 5


### be planning to, in your detailed comments, to 6


### provide more information abou t your thoughts 7


### concerning streamlining? 8


### I know mentioned that in you testimony. 9



### MS. GERMAIN: Yeah, I expect that we are 10


### going to be providing a lot of ideas and 11


### suggestions on what things we are hoping to see 12


### reductions in. In particular, they are probably 13


### going to be related to wellhead controls, because 14


### that’s where a lot of the really prescriptive 15



### standards come in, and that’s a lot of the areas 16


### where we think there’s opportunities, but there’s 17


### probably going to be significantly more than just 18



### t hat. 19


### MS. WARD: And I’m assuming the same 20


### thing for closed areas, or those of declining gas 21


### flows, you will have more detailed comments? 22

OLENDER REPORTING, INC. 1100 Connecticut Avenue, NW, #810, Washington, DC 20036

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### MS. GERMAIN: To try and reduce

-- yes, 1


### and that’s probably the reason we have to still 2



### develop some of those resp onses, and that’s 3


### probably the reason why we kind of need an 4


### extension to the 60 days, because to try and 5


### assemble all of that information and provide 6


### alternative suggestions to the EPA, we need a 7



### little more time. 8



### MS. WARD: Thank you. 9



### MR. RAGNAUTH: Nothing. 10


### MR. COZZIE: Thank you. Hillary hit on a 11


### couple of my questions as well about the 12


### streamline and the flexibility. You mentioned 13


### providing more flexibility and I guess my 14


### question is the same, will you provide more 15



### detail in a

-- in your subseq uent comments? 16


### MS. GERMAIN: Yes. We have an industry 17


### group that we have assembled to try and provide 18


### as much detail as possible, that we think will be 19


### representative of the entire industry, that we 20



### think are rules that will

-- adjustments that 21



### could be made that are going to either not reduce 22

OLENDER REPORTING, INC. 1100 Connecticut Avenue, NW, #810, Washington, DC 20036

Washington: 202

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### any

-- or not increase any emissions or, perhaps, 1


### even have a positive effect on emissions, but at 2


### the same time, give the industry the ability to 3


### have a lot more flexibility in the way they 4


### operate their systems

. 5


### Part of the problem is, sometimes there’s 6


### no real ability to document any reductions in 7



### emissions. It’s kind of more anecdotal, and so 8



### there’s no documentable information, but we can 9


### certainly demonstrate that it doesn’t increase. 10



### MR. COZZIE: All r ight, thank you. Thank 11


### you for your testimony, and will you be leaving a 12


### copy of that with registration? 13


### MS. GERMAIN: It’s kind of waterlogged 14


### but I would be happy to leave it. 15



### MR. COZZIE: Fine. It reads the same. 16



### Thank you very much. 17



### [CON VERSATION HELD OFF THE RECORD] 18



### MR. COZZIE: It is now 10:38 and with no 19


### other speakers signed up, I am putting the panel 20



### in recess. 21



### [WHEREUPON, A RECESS WAS TAKEN AT 10:38 22

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### AM. THE HEARING RECOMMENCED AT 11:45 AM] 1



### MR. COZZIE: The time now is 11:45, I 2


### will reconvene the panel. There are no speakers 3


### at this point. We will recess the panel until one 4



### o’clock this afternoon. 5



### [WHEREUPON, THE LUNCH BREAK WAS TAKEN AT 6



### 11:45 AM. THE HEARING RECONVENED AT 1:09 PM] 7



### MR. COZZIE: Good afternoon and welcom e 8


### to the public hearing on proposed updates to the 9


### new source performance standards for new solid 10


### waste landfills. We are reopening the panel at 11


### this point. I would like to recognize

-- 12


### acknowledge that Ms. Swarupa Ganguli has replaced 13



### Mr. Shaun Ragnauth on the panel. 14


### At this time we have no speakers. We 15


### will stay open and see if any speakers arrive. 16



### [WHEREUPON A RECESS WAS HELD AT 1:10 PM. 17



### THE HEARING RECOMMENCED AT 1:31 PM] 18



### MR. COZZIE: As we have no speakers at 19



### the moment, we will recess unt il any speakers 20


### sign up at the registration desk. 21



### Thank you. 22

OLENDER REPORTING, INC. 1100 Connecticut Avenue, NW, #810, Washington, DC 20036

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### [WHEREUPON, A RECESS WAS TAKEN AT 1:31 1



### PM. THE HEARING RECOMMENCED AT 5:57 PM] 2


### MR. COZZIE: Good evening. Welcome to 3


### the public hearing on municipal solid waste 4



### landfills. The time now i s 5:57. At this time I 5


### am reopening the meeting. There are no speakers 6


### signed up and we will officially close the 7


### meeting now. 8


### Thank you and have a great evening. 9



### [WHEREUPON, THE HEARING CONCLUDED AT 5:57 10



### PM] 11

12

13

14

15

16

17

18

19

20

21

22

OLENDER REPORTING, INC. 1100 Connecticut Avenue, NW, #810, Washington, DC 20036

Washington: 202

- 898

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- 752

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- 445

- 3376