DRAFT
MEETING
NOTES
Meeting:
May
28,
2003
Participants:
K.
C.
Hustvedt,
JoLynn
Collins,
EPA
Clint
Burklin,
Chad
Leatherwood,
ERG
Mike
Michaels,
EMCON/
OWT
Other
industry
reprentatives/
SWANA
Subject:
Discussion
of
January
14,
2003
letter
from
SWANNA
to
EPA
regarding
1­
hour
downtime
limit
in
Landfill
NSPS
for
control
devices.
______________________________________________________________________________

Industry
representatives
started
the
meeting
by
noting
that
they
wanted
to
get
a
status
of
EPA's
thinking
on
this
issue,
to
give
EPA
an
overall
view
of
current
enforcement
actions,
but
not
to
discuss
specific
enforcement
cases.
The
representatives
expressed
concern
over
the
difference
in
interpretation
of
the
1­
hour
control
device
downtime
issue
across
the
EPA
Regions.
Industry
interprets
this
requirement
in
the
NSPS
as
a
1­
hour
limit
of
free
venting
should
a
control
device
cease
operation.
This
would
be
accomplished
by
either
restarting
the
control
device
or
shutting
down
the
collection
system.
However,
some
Regional
Offices
are
interpreting
this
requirement
to
mean
that
a
source
has
1
hour
to
restart
the
control
device.
Industry
representatives
argued
that
this
is
not
a
realistic
time
frame
to
repair
and
restart
a
control
device
and
expressed
their
disagreement
with
EPA's
current
stance
on
this
issue.

The
representatives
stated
that
they
would
like
to
see
the
NSPS
revised
such
that
both
the
collection
system
and
control
device
have
a
5­
day
downtime
allowance
for
maintenance
or
malfunctions
and
that
they
are
comfortable
with
retaining
a
1­
hour
free
venting
limit.
KC
noted
that
the
Regional
interpretations
were
correct.
He
iterated
that
the
5­
day
limit
for
collection
system
repair
came
from
the
fact
that
it
may
take
a
week
to
repair
wells
and
other
components
of
the
collection
system,
but
gas
production
in
landfills
cannot
be
cut
off
like
industrial
processes.
While,
landfills
are
able
to
absorb
landfill
gas
for
a
period
of
time
once
a
collection
system
is
shutdown,
the
gas
will
ultimately
break­
out
of
the
landfill
if
collection
and
control
is
not
reestablished
soon.

KC
explained
that
there
are
two
extremes
where
this
issue
could
go:
1)
leave
it
alone,
or
2)
remove
the
requirement
from
the
NSPS
and
allow
the
NESHAP
SSM
plan
to
handle
the
issue.
KC
stated
that
there
should
be
somewhere
in
between
to
meet
on
this
issue.
The
industry
representative
suggested
that
maybe
a
surface
monitoring
requirement
could
be
added
to
the
NSPS
or
be
required
in
the
SSM
that
would
be
implemented
if
a
shutdown
lasts
for
longer
than
5
days.
KC
raised
the
point
that
if
a
system
fails
the
surface
monitoring,
the
current
solution
in
the
rule
is
to
increase
the
gas
collection
rate,
but
this
is
not
an
option
if
the
system
is
not
functioning.

Clint
questioned
the
representatives
over
how
common
it
is
to
have
a
back­
up
control
device.
The
industry
representative
noted
that
it
is
common
at
an
energy
recovery
facility,
but
not
common
where
landfill
gas
is
flared.

KC
questioned
how
industry
would
react
if
EPA
extended
the
control
device
downtime
allowance
to
5
days.
What
would
surface
monitoring
do?
Industry
representatives
noted
that
it
takes
many
days
of
downtime
before
surface
levels
exceed
500
ppmv,
but
industry
would
do
surface
monitoring
to
demonstrate
no
significant
fugitive
emissions.
They
noted
it
would
be
good
to
have
in
SSM
plans
to
confirm
emission
minimization.
KC
added
that
it
would
be
good
to
identify
areas
of
concern,
especially
to
locate
leaks
in
the
caps.
Industry
cautioned
that
this
surface
monitoring
would
only
be
good
for
longer
down
times
and
does
not
suggest
surface
monitoring
for
shorter
down
times
due
to
mobilization
and
cost.

The
industry
representative
questioned
EPA
as
to
it's
direction.
KC
responded
that
the
call
has
been
helpful
and
that
EPA
is
still
gathering
information.
KC
needed
to
talk
to
OGC,
enforcement,
and
regional
folks
and
then
suggested
another
meeting.
He
noted
that
EPA
has
14
MACT
standards
to
do
by
the
end
of
the
year
and
things
were
pretty
busy.

KC
asked
if
there
were
any
other
issues
to
discuss.
The
industry
representative
noted
that
the
proposed
amendments
did
raise
some
issues,
but
they
had
covered
them
in
comment
letters.
KC
explained
that
EPA
is
working
on
the
NSPS
amendments
and
will
try
to
catch
up
with
industry
representative
before
promulgation
to
provide
the
staff
level
recommendations.
KC
noted
that
EPA
wants
to
reduce
compliance
barriers
in
the
NSPS
amendments
and
questioned
how
the
1­
hour/
5­
day
downtime
issue
would
work
in
relation
to
off­
site
control
of
landfill
gas.
Industry
representative
noted
that
most
gas
collection
systems
have
pressure
gauges
that
automatically
divert
gas
to
a
back­
up
control
when
a
control
device
is
inoperable.
They
noted
that
SSM
plans
should
address
back­
up
control
issues.

Meeting
participants
agreed
to
look
into
scheduling
a
follow­
up
meeting
during
the
week
of
June
16th.
