1 MEETING NOTES

Meeting Date: August 18, 2009

Participants : See Attachment A

Subjects : Climate Legislation and Potential Impact on Landfills Sector Potential Revisions to the Current NSPS Bioreactors Monitoring (See Attachment B for Detailed Agenda)

______________________________________________________________________________ 1. Climate Legislation and Potent ial Impact on Landfills Sector

Waxman-Markey Climate Bill

 Landfills are not covered under the “capped” portion of the bill

 EPA has a fair amount of discretion in the bi ll to develop the offs ets program. Reductions must be real, measurable, “a dditional,” and “permanent.”

 Requirements for EPA to develop new source performance standards (NSPS) for sources >10,000 tons/yr CO 2 e. Has potential for tightened NSPS, which could reduce the availability of offsets.

California Assembly Bill 32: Global Warming Solutions Act (AB-32)

 California Air Resources Board (CARB) cap & trade bill to reduce greenhouse gas emissions

 “Early action measures” regulations for so me source categories, including landfills

 Reduce methane emissions from MSW landfills by requiring gas collection and control systems on landfills where these systems are not currently required

 Establish statewide performance standards to maximize methane capture efficiencies.

To develop the standard, the South Coast, Bay area, & NSPS were reviewed. New standard has:

 Surface methane monitoring with a limit of 500 ppm for any single location and 25 ppm integrated across all scanned locations, monitored on a 25 meter grid and integrated. (Industry preferred 50 ppm and is concerned that meeting 25 ppm might draw in too much air and cause fires.)

 Leak detection and repair (LDAR) requirements for valves, flanges, etc. for the part of the gas system that is under pressure (post-blower). If the landfill finds a leak for a boiler, then the leak gets fixed duri ng the next scheduled shutdown.

 No wellhead monitoring other than it has to be under vacuum2  400,000 tons of place trigger for landfills being studied

 Must comply by 2011

Landfills required to control by AB-32 would not be eligible for offsets due to the additionality criteria in offset programs.

2. Potential Revisions to the Current NSPS

EPA noted multiple obligations for MSW landf ills NSPS/EG/NESHAP, which EPA would like to consolidate and address at once.

 NSPS amendments

 Risk and technology review

 Environmental Defense Fund (EDF) notice of in tent to file a lawsuit to revise NSPS

Regarding the EDF notice of intent to file a la wsuit to revise NSPS, EDF stated that EPA:

 Failed to revise the NSPS on schedule

 Should set a separate methane standard

 Should update Best Demonstrated Technology (BDT) since 1996 for advances in technology

 Has a duty to update emission guidelines (EG)

 Could add a requirement in the rule or an incentive through other pr ograms to shift waste away from landfills (such as organic waste source separation).

Regarding the regulation of greenhouse gases (GHGs) and setting a methane standard, EPA noted:

 No decisions yet on regulating GHGs

 Could consider a “landfill gas” trigger in the NSPS without a finding/decision to regulate GHGs under the CAA

The group discussed different ways to achie ve additional NSPS reductions. General ideas mentioned by various participants and some related comments are listed below.

a. Source Separation of organics to reduce methane generation:

 CARB is currently studying organic waste di version using lifecycle analysis. LA County Sanitation District Representative indicated pr eliminary results from the draft study show that landfill lifecycle emissions look “pretty good” relative to other waste management options. Diversion would require siting of many compost facilities and waste-to-energy facilities throughout the state. To make informed decisions on separations, the issue would require further scientific examination and decision make rs would need to consider the practicability of siting.

 Tighter NSPS would increase the cost of waste disposal, and that al one would create an incentive for other solutions like organic waste diversion.3 b. Cap Requirements:

 Stronger cap requirements could get more collection (all types of cover - daily, intermediate, and final cover). Compost or mulch blankets promote oxidation of methane that is not collected.

c. EPA could set a target overall reduction and let each State determine how to meet it:

 For example, NSPS and EG targeted only la rger landfills, which in some cases could conflict with operational practices at active la ndfills. North Carolina has lots of closed landfills and it would be relativel y easy to put in wells (since the landfills are closed).

 However, some small old landfills have low-Bt u gas and are hard to control. So, small landfill control would probably better left to state/local le vel regulation.

d. Improved leak detection:

 Could evaluate various methods of sensing l eaks: LDAR, cameras, remote sensing. EPA has observed leaks around well heads and c onnection to leachate systems and header sites.

 Some participants indicated if you have a surface methane standard, you do not need the wellhead parameter monitoring and other design standards. This approach was taken in California.

 Others said surface monitoring test is made for diffused emissions and will not detect hot spots. Because the 30m grid can miss emissions, you need to sample every wellhead and every brown spot.

e. Once controls are installed, requi re them for a longer time period:

 In some cases it makes sense to keep controls on longer, but for some closed landfills, gas quality declines over time so that it is hard to meet wellhead standards.

f. Reduce barriers to LFG energy projects.

 In particular, the issue of whether the landfill or the owner/operator of an energy recovery project is responsible for NSPS complianc e and common control decisions in state permits can be barriers to LFG energy projects.

 This is a subject of previously proposed NSPS amendment notices

g. Provide incentives for Landfill Gas Energy but do not require them in the NSPS:

 Incentives work very well to encourage energy projects - tax incentives, GHG credits, offsets, etc. Rule should not re quire landfill gas energy projects.

 There was some concern that some energy proj ects are not well operated. Need to protect public health.4  Center for Competitive Waste Industry will di stribute an analysis (when it is final) showing concerns with landfill gas energy projects.

h. Require earlier installation of controls

 Consider changing the 2 and 5 years collecti on system expansion dates (for closed and active areas, respectively) to 1 and 3 years. Or could change the re quirement to install controls from within 30 months after r eaching the emissions threshold to within 21 months.

 Earlier control might recover lower qualit y gas and the landfill might need more flexibility in meeting the we llhead requirements (i.e., oxygen/ nitrogen, temperature, and pressure requirements in the NSPS)

i. Include a methane trigger for control installation:

If methane is the focus, the rule may come out stronger. Participants indicated if you have a surface methane standard, you do not need the we llhead parameter monitoring and other design standards. This approach was taken in California.

g. Consider full life of a landfill:

Significant emissions occur early in the life of a landfill, from active areas before a final cover is installed. Emissions can also occur late in a land fill’s life as the cover degrades. Typically, gas is not collected and controlled duri ng the early and late phases.

3. Bioreactors

 NCSU submitted a draft bioreactor report to EPA/ORD. The report had landfill data from three landfills (multiple cells at one of them). Decay rates from three landfills did not correlate with moisture content. Thus, 40% mo isture content might not be the best trigger for the NESHAP bioreactor provisions. The re port looked at water added per mass and liquid added per unit area.

 Many wet landfills have <40% moisture content so the NESHAP does not require early controls. Many landfills want to operate wet to reduce their leachate treatment costs or to get more waste in a given space. Regardless of whether it’s called a “bioreactor,” the end result is you get emissions sooner, a nd you should have to control accordingly.

 Liquid percent is hard to calcu late and is not even ly distributed. There is saturation near the distribution point, but dry further away. Over time, the moisture front spreads.

4. Monitoring

 Other Test Method 10 (OTM10) was posted in 2006 for area source measurements. EPA has been working to understand and improve the method’s performa nce for large area sources (landfills) and has developed a model to calculate emissions per square meter.5 EPA is summarizing the data and will publish it and revise OTM10 to clarify its use for landfills.

 Still looking at additional ways to measure em issions from large area sources, including a mobile tracer approach.

 Could look at an array of possible measuremen t practices. Not sure if any remote sensing would be appropriate for the NSPS or the ru le would retain more of a leak-detection approach.

 Cost of OTM10 is about $25,000 per week, not including buying instruments. EPA acknowledges this is costly, but hopes to have non-proprietary and lower cost approaches in the next few years.

 Several participants indicated that cost and technical difficulty make OTM10 not appropriate for a rule. Surface monitoring is su fficient to measure the effectiveness of the gas system. The Ray Hurtrich papers correla te surface monitoring with flux box emission
rate measurements.

 A handheld monitor could be used to ch eck boots around wellheads. Remote sensing would measure emissions only infrequently and in a very costly way and is not necessary to see if a collection system is working. It’s better to go out and look for the broken piece of rubber, and monitor around well conn ectors for leaks/high concentrations.

 EPA keeps getting questions on gas collecti on efficiency. EPA plans testing at some landfills using OTR and gas collection syst ems measurement to try to get good data.

 Flux box techniques are used for different appl ications such as comparing covers. There are many peer reviewed scientific papers on applications of this technique.

 There was a concern about whether remote se nsing methods could be used to determine working face and side slope emissions. EPA acknowledged in some cases it is hard to collect working face data due to operational issues. But, generally, it is important to collect working face data because that is wh ere most emissions are occurring. Regarding side slopes, wind flow causes plumes to move in different ways and the way the plumes encounter the optical plane is complex.6 Attachment A

MSW Landfill Stakeholder Attendee List

MSW Landfill Stakeholder Meeting Attendees Affiliation Hillary Ward USEPA
Ken Hustvedt USEPA
Rick Vetter USEPA
Susan Thorneloe USEPA
Tom Driscoll USEPA
Tom Frankiewicz USEPA
Eben Thoma USEPA Robin Segall USEPA Paul Chrissman NC Dept of Environment and Natural Resources

Ed Mussler NC Dept of Environment and Natural Resources
Elizabeth Paranhos EDF Brian Bahor Covanta Energy Services Amy Banister-Von Kolken Waste Management Kerry Kelly Waste Management Ed Repa NSWMA Angela Marconi DSWA Niki Wuestenberg Republic Services Morton Barlaz NC State University Kate Bailey Ecocycle Frank Caponi LACSD
Shannon Crawford SWANA Peter Anderson Center for Competitive Waste Industry
Dick Ball Sierra Club
David Frieland B&D
Ruth Mead ERG Joe Fanjoy ERG7 Attachment B

MSW Landfill Stakeholder Meeting August 18, 2009 USEPA Research Triangle Park, Ma in Campus, Conference Room C 111 B Conference Line: (919) 541-4328

I. Introductory Comments

II. General Discussion: Climate Change Legislation and Potential Impact on Landfills Sector

III. General Discussion: Potential Revision to the Current NSPS

IV. General Discussion: Current NESHAP De finition of Bioreactor Landfills and Potential Use of Metrics Other Than Water Content

V. General Discussion: Flux Box Measurements vs. Optical Remote Sensing

VI. Adjourn