SWANA, NSWMA Address Proposed EPA Landfill Emission Factors

The Solid Waste Association of North America (SWANA) and the National Solid Wastes Management Association (NSWMA) on May 5 submitted joint comments on the U.S. Environmental Protection Agency's proposed revisions to AP-42, Fifth Edition, Volume I, Chapter 2.4 Municipal Solid Waste Landfills and the Background Information Document for Updating AP-42 Section 2.4 for Estimating Emissions from Municipal Solid Waste Landfills. These emission standards are very important to the landfill industry because they affect federal, state, and local air quality permits.

Bruce J. Parker, NSWMA president and chief executive officer, stated that: "Both public and private landfill owner/operators have an important stake in ensuring that EPA's Final AP-42 guidance truly represents the emissions occurring at their landfills." John H. Skinner, executive director and chief executive officer stated that: "SWANA was very pleased to work with NSWMA to provide substantial data to EPA that we believe will significantly improve the emission factors in the EPA document."

NSWMA and SWANA expressed concern on:

  • The rejection of non-methane organic compounds concentration data from NSPS/EG Tier 2 studies using the geoprobe method; and
  • The rejection of data submitted in 2000 and 2001 and the failure of EPA to advise of the rejection until 2009.

The two associations hope that through the further review of new data submitted by their members and a thorough review of current published technical literature, EPA can revise the draft AP-42 and background information document accordingly.