On May 5, NSWMA joined the Solid Waste Association of North America (SWANA) in submitting comments on the EPA’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. NSWMA and SWANA expressed concern on the following issues:
- 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.
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