White Paper: Impact on the Waste Industry from Proposed EG and Supplemental NSPS Rules for Landfills

A&WMA’s 109th Annual Conference & Exhibition
New Orleans, Louisiana
June 20-23, 2016

Cassandra B. Drotman, Raymond H. Huff SCS Engineers, Long Beach, California, and Patrick S. Sullivan SCS Engineers, Sacramento, California


The Supplemental NSPS and Proposed EG are going to significantly modify operations and maintenance at landfills. The proposed rules both increase the stringency for installation of a GCCS system as well as providing the Tier 4 method to postpone GCCS installation. Overall, there is expected to be a significant increase of the monitoring required, date collection requirements, and cost of operating a landfill. Some flexibility is given with the new proposed definitions and removal of a few requirements which will slightly lessen the increased requirements in other areas.

EPA has proposed the final rules will be published in July 2016. It is yet to be seen what the cost of the proposed rules updated monitoring and recordkeeping requirements will be. The landfill industry will need to wait and see how the promulgated rules affect landfills both in the near- and long-term.


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