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MSW Landfill NSPS and Guidelines Issued

The MSW Landfill NSPS (Subpart XXX, formerly Subpart WWW) and Guidelines (Subpart Cf, formerly Cc) were signed on July 14, 2016.

  • The NSPS is for landfills that commence construction after July 17, 2014.  The Guideline is for existing landfills that commenced construction on or before July 17, 2014.
  • The new rules maintain the design capacity thresholds of 2.5 metric tons (Mg) and 2.5 million cubic meters for requiring that NMOC’s be calculated annually.
  • The new rules lower the threshold for requiring collection and control from 50 Mg/yr to 34 Mg/yr.

The Guideline retains the option to route LFG to a treatment system that processes the collected gas for sale or beneficial use but now provides more specific monitoring requirements:

  • Continuous monitoring of gas flow;
  • Monthly visual inspection of the bypass line valve position;
  • Records of gas flow and bypassing of the system; and
  • Site-Specific Treatment Monitoring Plan – records of filtration, de-watering, and compression parameters (which the facility has to propose), monitoring methods/ranges, responsible personnel for data collection, data collection processes, QA, maintenance, and repair of continuous monitoring systems.

Final Rules available here:  https://www3.epa.gov/airtoxics/landfill/landflpg.html

These rules will not be effective until they are published in the Federal Register and incorporated into each State Implementation Plan (SIP).  So, the rule changes are expected to be effective in late 2017.