Air and Waste DEQ Guidance for Early Detection and Management of ETLFs

September 18, 2026

Virginia DEQ’s recently published guidance establishes a coordinated air, solid-waste, and financial-assurance framework to detect and manage elevated-temperature conditions at municipal solid-waste landfills.  This guidance became effective September 12, 2026.

The DEQ’s primary goals are to:

• Help landfills take a proactive approach to temperature and gas monitoring before severe environmental damage occurs.
• Help facility owners and operators carry adequate financial backing to cover mitigation, odor control, and remediation costs.
• Set clear operational guidelines to stop unpermitted leachate discharges, noxious odors, and severe waste settlement.

SCS Engineers describes below how the Virginia DEQ guidance establishes a three-tier framework for detecting and managing elevated-temperature landfill (ETLF) conditions at municipal solid-waste landfills subject to MACT AAAA temperature standards.  We briefly describe the category and action items. For infrastructure planning and financing, see additional resources below.

Category 1—lowest risk—includes landfills required to comply with the operational temperature standard in 40 CFR 63.1958(c) that do not have an approved temperature HOV greater than 145°F.  Corrective Actions Include:

• Monitoring methane, carbon dioxide, and the CH₄:CO₂ ratio at each regulated well monthly and reporting results electronically to DEQ.
• Evaluate and notify DEQ within 30 days when the ratio falls below 0.9.
• Track leachate volumes, maintain rolling five-year graphs, and conduct at least annual sampling for specified constituents.
• Report unusual conditions within 24 hours verbally and five working days in writing.
• Update financial assurance for added monitoring costs.

Category 2—elevated risk—includes landfills with MACT AAAA HOV Demonstration Approvals between 150°F and 170°F, but no approved allowance to operate above 170°F. Corrective Actions Include:

• Adding monthly monitoring for carbon monoxide and hydrogen.
• Conduct weekly monitoring when oxygen is at least 2%, and temperature exceeds 145°F.
• Submit a solid-waste permit modification and updated Leachate Management Plan,
• Increase leachate sampling to quarterly; add benzene, methyl ethyl ketone, and phenol testing; evaluate affected cells separately where possible,
• Stop leachate recirculation in areas showing ETLF indicators.
• Update gas-management plans, infrastructure, and financial assurance as needed.

Category 3—confirmed ETLF—includes landfills with MACT AAAA Applicable Gas Collection Wells Exhibiting Hydrogen (H2) greater than 5% or temperatures greater than 170°F that cannot be corrected within 15 days. Corrective Actions and Notes Include:

• DEQ will no longer approve temperature limits above 170°F, and existing approvals expire six months after the guidance date.
• Facilities must submit an amended Gas Collection and Control System Design Plan within 120 days of an exceedance.
• Update odor and leachate-management plans, and
• Obtain a permit modification incorporating an ETLF Corrective Action Plan.

Category 3 corrective actions may also include installing or replacing gas wells and heat-sensitive infrastructure, increasing gas extraction and leachate removal, expanding leachate storage and treatment, increasing sampling, stopping recirculation and waste placement, improving odor controls, and temporarily or permanently capping affected areas.

All three categories must revise cost estimates and increase financial assurance within 30 days after DEQ approves the updated estimates.

Publications and Additional ETLF Resources:

• Electronic copy of this guidance is available on the Virginia Regulatory Town Hall under the Department of Environmental Quality (DEQ) and the DEQ website.
• Identifying and Managing Elevated Temperature Landfills – Educational Video features an overview of ETLFs, engineering strategies in seven steps, and practical advice for operating and managing a landfill with elevated temperatures.

We know much more now than decades ago and can diagnose and control ETLF conditions. It is still labor-intensive and expensive, but with landfill technology and expert guidance, you can identify and help prevent severe high-temperature conditions that, if left undiagnosed, can damage the landfill’s infrastructure and systems.

• Contact a landfill expert near you for a gap analysis, master planning, or infrastructure financing.
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