Uncertainty EPA Regulations Created with New NSPS XXX and Cf Rules

Presented at A&WMA’s 113th Annual Conference & Exhibition

Landfill owners and operators remain in a state of limbo. Some sites are complying with Subpart XXX and dealing with the duplicate requirements from Subpart WWW and other issues. Several states have approved Cf EG rules, so landfills in those states must begin to comply with those state rules. Several other states have proposed state plan approvals and could see approved EG rules issued soon, as in the Commonwealth of Virginia.

This paper updates landfill owners and operators on the status of multiple regulations, including Subpart WWW and Cc (Old NSPS and EG), Subpart XXX and Cf (new NSPS and EG), NESHAP Subpart AAAA, and the compliance strategy being used by landfills during this period of limbo.

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