Uncertainty EPA Has Created with New NSPS XXX Cf Rules

摘要

1.The U.S. Environmental Protection Agency (EPA) has created confusion with its most recent versions of the municipal solid waste (MSW) landfill New Source Performance Standards (NSPS) and Emission Guidelines (EG) [40 Code of Federal Regulations (CFR) Part 60, Subparts XXX and Cf 2.The NSPS XXX and EG Cf rules do not give clear on and off ramps from the old NSPS Subpart WWW and EG Subpart Cc rules and have various inconsistent and overlapping requirements. 3.EPA made matters worse by not updating the MSW landfill National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 63 Subpart AAAA, rule at the same time. 4.This created a situation where both the old and new rules could apply simultaneously (with conflicting requirements), even though the new rules were supposed to replace the old rules.