May 21, 2021

landfill emissions

(40 CFR Part 60, Subpart OOO)

On May 21, 2021, EPA published the final MSW Landfills Federal Plan, which implements the 2016 Emission Guidelines (EG Subpart Cf) under 40 CFR Part 62 Subpart OOO.  The Federal Plan becomes effective June 21, 2021, and impacts landfills that have not triggered NSPS Subpart XXX requirements and landfills located in states and Indian country without EPA-approved EG Cf rules.

Affected are MSW landfills that commenced construction on or before July 17, 2014, and have not been modified or reconstructed since July 17, 2014.

The Federal Plan requires existing landfills that reach an annual emissions threshold of 34 metric tons of nonmethane organic compounds (NMOC) or more to install a system to collect and control landfill gas (GCCS).  It also implements various emission limits, compliance schedules, testing, monitoring, reporting and recordkeeping requirements for GCCSs established in the 2016 Emission Guidelines for MSW Landfills.

The Federal Plan also establishes a definition for “legacy controlled landfills.”  These are landfills that have previously satisfied the requirement to submit an initial design capacity report, initial (or annual) NMOC emission rate reports, and collection and control system design plan under 40 CFR part 60, subpart WWW; 40 CFR part 62, subpart GGG; or a state/tribal plan implementing 40 CFR part 60, subpart Cc.

If you are subject to the Federal Plan and are not a “legacy controlled landfill,” you must submit a design capacity report by September 20, 2021.  And if the design capacity report indicates a capacity equal to or greater than 2.5 million Mg and 2.5 million m3 of solid waste, you must also submit an initial NMOC emission rate report within 90 days after the effective date of the Federal Plan (September 20, 2021).

SCS is working to develop a Technical Bulletin for distribution to our mailing list and on social media. The Bulletin will consolidate the Final Rule into several pages highlighting significant dates and key impacts for you.







Posted by Diane Samuels at 3:17 pm