Enforcement Alert: Solid Waste. U.S. EPA Enforcement Initiative for Landfills to Meet Greenhouse Gas Compliance

The United States Environmental Protection Agency (U.S. EPA) recently issued an Enforcement Alert signaling a critical move toward stricter regulation of municipal solid waste (MSW) landfills to address non-compliance with air quality standards, specifically around monitoring and controlling greenhouse gas (GHG) emissions. This alert follows an investigation revealing that many landfills are not fully adhering to federal regulations designed to reduce emissions of methane, a potent greenhouse gas that contributes significantly to global warming, as well as other harmful pollutants like volatile organic compounds (VOC) and hazardous air pollutants (HAP). 

Why Landfill Emissions Matter 

Although methane naturally results from the anaerobic decomposition of organic waste, landfill operations are legally required to capture and control these emissions to minimize their environmental and public health impacts. Methane has a global warming potential over 25 times greater than that of carbon dioxide over a 100-year span, making its containment critical for climate mitigation efforts. VOC and HAP emitted along with methane can contribute to smog, respiratory issues, and other health hazards, putting nearby communities at risk. 

U.S. EPA’s alert highlighted several issues related to gas collection and control systems (GCCS), surface emissions monitoring, and the maintenance of landfill covers—all of which are essential in controlling emissions. The alert pointed to inadequate design, maintenance, or operation of GCCS, inconsistent surface emissions monitoring, and poor landfill cover integrity as issues that increase the likelihood of methane leaks. The failure to properly manage these systems has led to emissions that exceed permissible levels, posing both environmental and health risks. 

Key Compliance Requirements 

Under the Clean Air Act (CAA), landfills must follow stringent requirements to control emissions. These requirements are designed to limit GHG emissions and protect communities living in close proximity to landfills. U.S. EPA enforces rules covering: 

• Gas Collection and Control System Operation: Proper design, maintenance, and operation of GCCS are essential for capturing and combusting landfill gas, thereby reducing methane emissions. Landfills are required to install GCCS within a specific timeframe and continuously operate and maintain the system. 
• Surface Emissions Monitoring: Landfills must conduct regular surface monitoring to detect and address leaks of landfill gases, particularly methane, from the soil surface. Any detected leaks must be promptly repaired to prevent excess emissions. 
• Landfill Cover Integrity: Effective cover systems are critical for containing emissions. Covers must be maintained to prevent cracks or openings through which methane and other gases could escape. The use of appropriate materials and regular checks are fundamental in ensuring cover integrity. 

U.S. EPA’s Increased Focus on Enforcement 

U.S. EPA is implementing stricter enforcement measures. These may include increased inspections, fines, and requirements for corrective actions for operators who fail to adhere to the standards. U.S. EPA’s goal is not only to mitigate the environmental impact of landfill emissions but also to protect the health of nearby residents who may be exposed to air pollutants from landfill operations. 

The recent enforcement focus reflects a broader commitment to reducing methane emissions under the current administration’s climate goals. This could be subject to change after the new administration takes office. Reducing methane is essential for meeting the U.S. GHG reduction targets. As such, U.S. EPA has placed landfill emissions control as a high priority within its enforcement strategy. This move aligns with both domestic and international efforts to curb short-lived climate pollutants, which have a strong impact on near-term climate change. 

Recommendations for Landfill Operators 

U.S EPA is advising landfill operators to review their GCCS, surface monitoring procedures, and cover maintenance practices to ensure compliance. Operators are encouraged to conduct internal audits, enhance staff training on emissions controls, and proactively monitor equipment to avoid compliance issues.  

The Enforcement Alert is a reminder that non-compliance not only leads to potential penalties but also poses significant environmental and health risks for neighboring communities. U.S. EPA’s call for enhanced compliance signals a shift toward stricter oversight and accountability for MSW landfills as part of the broader effort to reduce GHG emissions in the United States. As landfill operators adjust to these expectations, they play a crucial role in supporting climate action and protecting the communities they serve. 

For a detailed review of the U.S. EPA’s findings and compliance guidance, you can view the full U.S. EPA Enforcement Alert here. 

ALL4 is here to help you understand how U.S EPA landfill emissions enforcement may affect your operations and support you in meeting compliance requirements. For questions or further assistance, please reach out to me, Ashley Brooks, at abrooks@all4inc.com or contact your ALL4 project manager.