On Tuesday, September 25, the U.S. Environmental Protection Agency (EPA) issued two enforcement alerts addressing regulatory requirements and associated compliance issues at municipal solid waste landfills (MSW landfills). The alerts address Clean Air Act requirements that control the release of landfill gases (LFG), particularly methane, from MSW landfills.
These reminders represent compliance issues that EPA has flagged during enforcement actions. EPA thought they were important enough to publish these alerts for the benefit of landfill OM&M; expect state and local agencies to focus on these during their regulatory inspections.
The alerts provide an overview of the Clean Air Act regulatory requirements related to landfill air emissions and aim to help landfill owners, operators, and contractors comply with the law and take the necessary steps to avoid potential EPA enforcement actions.
The first enforcement alert, “EPA Investigations Find Municipal Solid Waste Landfill Operators are Failing to Properly Conduct Compliant Monitoring and Maintenance of Gas Collection and Control System,” is intended to remind MSW landfill owners, operators, and their consultants to conduct routine monitoring and maintenance of gas collection systems to ensure all landfill emissions are being properly captured and controlled.
The second enforcement alert, “MSW Landfill Operators Fail to Include Wastes from Total Degradable Waste-in-Place and Properly Sample Landfill Gas, Resulting in Underreported Emissions,” is intended to remind MSW landfill operators, owners, and their consultants to identify and document nondegradable wastes excluded in calculations properly and to collect representative LFG samples for non-methane organic compounds analysis and emission calculations.
If you are operating a landfill that gets an EPA Section 114 request for data, is having or has had an EPA inspection, or has received an EPA NOV, you may want to contact the compliance experts at SCS Engineers to seek advice on EPA’s perspective on rule history, interpretation, and assist how best to prevent or defend against enforcement actions.
Additional Resources
The EPA and, in some cases, states are rolling out new emissions guidelines at least as stringent. The EPA estimates that the plans could cover about 1,600 landfills. These landfills are in 41 states, tribal entities, and the U.S. territories of Puerto Rico and the Virgin Islands.
MSW landfills without Gas Collection and Control Systems (GCCS) that reach a specific threshold will need to add these systems and have 30 months to install or update control systems to meet new standards. As you’ve noticed by now, we’ve greatly oversimplified what is happening.
The new regulations and timetables are difficult to understand and untangle. SCS Engineers, in concert with SCS Field Services, have prepared resources to help during the transition period and afterward when landfills are likely to need more monitoring and measurement, thus creating millions of more bits of data to store, analyze, and report.
We hope you find these resources useful. We will be publishing more soon.
These resources may help you with future monitoring and maintenance:
Thank you to the many folks attending SCS’s live webinar on July 15th about managing the NESHAP, NSPS/EG transition period. As promised, we’ve created a library of resources for you to use and share with your colleagues.
These resources may help you with future monitoring and maintenance:
We’re here to help. Please find an expert or contact us at .
In an increasingly complex regulatory world, Remote Monitoring and Control (RMC) systems provide the tools necessary to improve safety, increase efficiency and make the right decisions quickly. Beyond capturing and storing data, these systems can sort through mountains of data, identify what’s important and deliver meaningful information to operators in real time or as needed.
Some of the added benefits of using RMC systems include:
Read the Waste Today article – click here. Learn more about Remote Monitoring and Control here.
