Shaping regulatory policies: How can SWANA influence and assist states in the development of sound landfill gas regulations under NSPS?
Ever since the development of the USEPA`s New Source Performance Standards (NSPS) for MSW Landfills began more than eight years ago, it proceeded under the close scrutiny and constructive criticism of SWANA and other municipal organizations, who considered it as being impractical, too expensive, overly detailed and highly theoretical. The initial draft of the NSPS Rule was issued in 1991 over the strong objections of SWANA, which felt that it contained too many theoretical and unproven tests and procedures, as well as a number of impossible-to-achieve standards. All in all, SWANA has submitted six sets of formal comments to EPA, aimed at making the rule more realistic and achievable, while minimizing its theoretical aspects. SWANA`s input to the EPA has had a positive effect on the content of the NSPS Rule. For example, after SWANA showed conclusively that several presumptions in the 1991 draft were in error, revisions were issued in 1993 and 1994. Most recently, SWANA`s input in January 1995 resulted in the main thrust of the final rule being changed from a design and proscriptive standard to a performance standard, and the threshold size of landfills subject to the rule being raised from one to 2.5 million metric tons, which reflects a more realistic standard aimed at the large landfills, which are the most significant emitters. As a result of SWANA`s efforts, the final rule, although still not perfect, is more reasonable and realistic than its predecessors.
- OSTI ID:
- 381466
- Report Number(s):
- CONF-9603165--
- Country of Publication:
- United States
- Language:
- English
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