EPA Finds MSW Landfills are Violating Monitoring and Maintenance Requirements
The United States Environmental Protection Agency (“EPA”) issued an Enforcement Alert (“EA”) titled:
EPA Finds MSW Landfills are Violating Monitoring and Maintenance Requirements.
The EA states that EPA investigations have found municipal solid waste landfill (“MSW”) operators failing to:
…Properly conduct compliant monitoring and maintenance of gas collection and control system.
The EA is stated to be intended to provide a reminder to the following of their obligation to conduct proper monitoring techniques and system maintenance to ensure compliance with the Clean Air Act’s MSW landfill requirements to MSW landfill:
Operators and owners.
Consultants.
The EA states:
- MSW landfills are the third largest source of methane emissions in the United States.
- More than 100 inspections over the past three years indicate that many operators are not complying with the Clean Air Act’s applicable regulatory requirements.
The EA identifies as compliance issues:
- Improper monitoring resulting in excess surface emissions of methane.
- Failure to properly design, install, operate, and maintain the gas collection and control system.
- Failure to maintain adequate MSW landfill cover integrity.
Note that certain MSW landfills could be subject to a combination of the following Clean Air Act standards:
- New Source Performance Standards, 40 C.F.R. part 60 subpart XXX.
- State or federal plans implementing the Emission Guidelines, 40 C.F.R. part 60 subpart Cf.
- National Emission Standards for Hazardous Air Pollutants, 40 C.F.R. part 63 subpart AAAA.
The EA can be downloaded here.
SDGs, Targets, and Indicators
| SDGs | Targets | Indicators |
|---|---|---|
| SDG 13: Climate Action | 13.2: Integrate climate change measures into national policies, strategies, and planning | The article highlights the failure of MSW landfill operators to properly design, install, operate, and maintain the gas collection and control system, resulting in excess surface emissions of methane. This indicates a lack of integration of climate change measures into the operations of these landfills. |
| SDG 11: Sustainable Cities and Communities | 11.6: Reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste management | The article mentions that MSW landfills are the third largest source of methane emissions in the United States. This indicates a failure to effectively manage municipal waste, leading to adverse environmental impacts. |
| SDG 3: Good Health and Well-being | 3.9: By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water, and soil pollution and contamination | The article states that MSW landfill operators are failing to properly conduct compliant monitoring and maintenance of gas collection and control systems. This can lead to the release of hazardous chemicals and pollutants, posing risks to public health. |
Source: jdsupra.com
