The Virginia Department of Environmental Quality (DEQ) has issued guidance titled Early Detection and Management of Elevated Temperature Landfills. The guidance establishes a tiered framework for identifying and managing landfill conditions that may indicate elevated temperature landfill (ETLF) activity. The guidance became effective September 12, 2026, following a public comment period that closed August 12, 2026.
The guidance is especially relevant for facilities with gas collection wells operating under higher operating temperature values (HOVs), increasing wellhead temperatures, elevated hydrogen, or leachate quality trends that may warrant additional evaluation.
Virginia DEQ will be reaching out directly to facilities with existing approved HOVs and will also work with facilities on permit amendments outlined in the guidance document and applicable implementation due dates.
DEQ’s guidance is intended to promote earlier recognition of ETLF conditions and to establish more consistent expectations for facility monitoring and response. The Guidance categorizes all Virginia landfills subject to the Landfill Gas Collection and Control requirements of 40 CFR 63 Subpart AAAA into three categories, primarily based on landfill gas wellhead temperatures, hydrogen concentrations, and related indicators. Each category carries progressively more detailed monitoring, reporting, leachate management, permitting, and corrective action expectations.
Category 1 – No Temperature HOVs above 145°F. Category 1 facilities must submit monthly landfill gas reports, conduct annual leachate sampling, track leachate volumes sent offsite, and review financial assurance. DEQ notification is expected if a gas collection well’s methane-to-carbon dioxide ratio is less than 0.9.
Category 2 – Temperature HOVs between 150°F and 170°F. Category 2 facilities are subject to the Category 1 requirements, along with additional monitoring for carbon monoxide and hydrogen at wells with HOVs. If oxygen exceeds 2%, enhanced monitoring is expected. Category 2 facilities must also update the Leachate Management Plan through a solid waste permit modification and conduct quarterly leachate sampling from relevant sump risers. Additional leachate sampling constituents under Category 2 include benzene, methyl ethyl ketone, and phenol.
Category 3 – Hydrogen above 5% or Temperatures above 170°F not corrected within 15 days. A Category 3 facility is generally considered an ETLF under the guidance. Category 3 requirements may include updates to the GCCS Design Plan, Odor Management Plan, Operations Manual, Leachate Management Plan, and related permit documents; implementing an ETLF Corrective Action Plan; ceasing waste placement in the ETLF area; and initiating permitting for temporary or final capping in the high-temperature area.
In addition, existing established HOVs for well temperatures greater than 170 will be considered expired after 6 months (i.e., by March 12, 2027), and VDEQ will no longer approve HOV requests above 170 deg F. Existing established HOVs may be canceled by a facility by notifying the VDEQ regional office.
Permit Modifications and Plan Updates. Depending on the facility category and observed conditions, the guidance may require updates to existing solid waste permit documents, including the Leachate Management Plan, GCCS Design Plan, Odor Management Plan, Operations Manual, and corrective action documentation. Facilities with existing temperature HOVs should pay close attention to deadlines and whether the updated plan documents support continued operation under those HOVs.
VDEQ will be reaching out directly to facilities with existing approved HOVs and will also work with facilities on permit amendments outlined in the guidance document and applicable implementation due dates.
Corrective Action and Operational Response. For facilities that meet Category 3 conditions, DEQ expects a more formal corrective action approach. This may include defining the ETLF area, evaluating landfill gas and leachate controls, ceasing waste placement in the affected area, and initiating appropriate capping or closure-related permitting. Early documentation will be important to support discussions with DEQ and to demonstrate that observed conditions are being actively evaluated.
The SCS team has a long history supporting Virginia landfills. With our strong portfolio in LFG collection and control systems (GCCS), identifying and managing elevated temperature conditions, leachate sampling, and liquids management, SCS Engineers can help Virginia landfills comply with the new VDEQ guidance. As an initial step, we recommend evaluating your landfill’s current status against the new requirements and landfill categories, and developing a long-term compliance strategy, including budgeting considerations, if needed.
For questions regarding the Virginia DEQ ETLF guidance or assistance evaluating facility-specific impacts, contact SCS Engineers. SCS can help landfill owners and operators review monitoring data, assess category status, evaluate leachate sampling and reporting obligations, prepare permit or plan updates, and develop corrective action strategies where needed.
Additional ETLF Resources In Virginia:
