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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 Potential 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 bill to develop the offsets program. Reductions 

must be real, measurable, “additional,” and “permanent.” 

 Requirements for EPA to develop new source performance standards (NSPS) for sources 

>10,000 tons/yr CO2e. 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 some 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 during the next scheduled shutdown. 

 No wellhead monitoring other than it has to be under vacuum 
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 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 landfills 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 intent to file a lawsuit to revise NSPS 

Regarding the EDF notice of intent to file a lawsuit 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 programs 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 achieve 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 diversion using lifecycle analysis. LA County 

Sanitation District Representative indicated preliminary 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 makers would need to consider 

the practicability of siting. 

 Tighter NSPS would increase the cost of waste disposal, and that alone would create an 

incentive for other solutions like organic waste diversion. 
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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 larger landfills, which in some cases could 

conflict with operational practices at active landfills. North Carolina has lots of closed 

landfills and it would be relatively easy to put in wells (since the landfills are closed). 

 However, some small old landfills have low-Btu gas and are hard to control. So, small 

landfill control would probably better left to state/local level regulation. 

d. Improved leak detection:

 Could evaluate various methods of sensing leaks: LDAR, cameras, remote sensing. EPA 

has observed leaks around well heads and connection 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, require 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 compliance 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 require landfill gas energy projects. 

 There was some concern that some energy projects are not well operated. Need to protect 

public health. 
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 Center for Competitive Waste Industry will distribute 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 collection system expansion dates (for closed and 

active areas, respectively) to 1 and 3 years. Or could change the requirement to install 

controls from within 30 months after reaching the emissions threshold to within 

21 months. 

 Earlier control might recover lower quality gas and the landfill might need more 

flexibility in meeting the wellhead 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 wellhead 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 landfill’s life as the cover degrades. Typically, gas is 

not collected and controlled during 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% moisture content might not be the best trigger 

for the NESHAP bioreactor provisions. The report 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, and you should have to control accordingly. 

 Liquid percent is hard to calculate and is not evenly 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 performance for large area 

sources (landfills) and has developed a model to calculate emissions per square meter. 
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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 emissions from large area sources, including a 

mobile tracer approach. 

 Could look at an array of possible measurement practices. Not sure if any remote sensing 

would be appropriate for the NSPS or the rule 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 sufficient to measure the effectiveness of the 

gas system. The Ray Hurtrich papers correlate surface monitoring with flux box emission 

rate measurements. 

 A handheld monitor could be used to check 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 connectors for leaks/high concentrations. 

 EPA keeps getting questions on gas collection efficiency. EPA plans testing at some 

landfills using OTR and gas collection systems measurement to try to get good data. 

 Flux box techniques are used for different applications such as comparing covers. There 

are many peer reviewed scientific papers on applications of this technique. 

 There was a concern about whether remote sensing 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 where 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. 
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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 ERG 
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Attachment B 

MSW Landfill Stakeholder Meeting 

August 18, 2009 

USEPA Research Triangle Park, Main 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 Definition of Bioreactor Landfills and 

Potential Use of Metrics Other Than Water Content 

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

VI. Adjourn