1162283 - Compliance with New Landfill Air Regulations

Over the past 10 years the United States Environmental Protection Agency (EPA) have reached out to the solid waste industry and other interested parties in preparation for several rounds of revisions to the New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs). Historically landfills have been subject to the NSPS Subpart WWW or Emission Guidelines (EG) Cc and the NESHAP AAAA regulations. As rules were finalized in the 1990s, landfills have been complying with these regulations for over 20 years.

Although it was long expected that revisions would be made to the NSPS and NESHAP regulations, as required by law, no one could have predicted how these historic rules would be revised and implemented over the course of the next 5 years. In August 2016, the NSPS Subpart XXX regulations and the Emissions Guidelines (EG) Subpart Cf were finalized. In March 2020, the NESHAP Subpart AAAA regulations were revised. On May 21, 2021, EPA's Federal Plan Subpart OOO implementing the EG Subpart Cf was published in the Federal Register. The Federal Plan became effective on June 21, 2021. Multiple states have EPA approved State Plans and these states will follow the State Plans instead of the Federal Plan. The level of involvement from the landfill industry was strong, as EPA sought comments and information from those who know and understand the current NSPS and NESHAP regulations and where these rules needed to be revised and improved. As the waves of new regulations began rolling out, landfills are left scrambling to not only understand how the new and revised regulations would impact site operations, but also just to understand what rules apply and what actions would be needed. It was no longer just two rules, but several overlapping rules and timetables with similar but not identical requirements. Not only that, but the operating permits for the site may reflect past applicable regulations.
This presentation will examine several case-studies of actual landfills across the country and how they navigated the evolving regulatory network. It will also discuss the interconnectedness of complying with the NSPS/NESHAP regulations that apply to landfills.