Comments were submitted to the EPA from NWRA/ SWANA regarding the EPA’s Advance Notice of Public Rule Making (ANPRM) for revisions to Subtitle D, and in particular potential revisions regarding the bulk liquids addition. Subtitle D prohibits bulk liquids additions with the exception of leachate recirculation, and the RD&D permit process allows bulk liquids. Bob Gardner of SCS Engineers was involved in the development of the joint NWRA/SWANA comment letter.
EPA has indicated that they are considering adding a “wet landfill” definition to Subtitle D; however, the Industry strongly advised against doing so. The letter addresses this issue and the reasons for recommending against a separate “wet landfill” definition.