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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
20-P-0236
July 30, 2020
Why We Did This Project
We conducted this audit to
determine whether active
municipal solid waste landfills are
operating under the appropriate air
quality permit. As waste in an
MSW landfill decomposes, it emits
methane, carbon dioxide, and
nonmethane organic compounds
that can cause adverse health and
environmental effects. The Clean
Air Act and U.S. Environmental
Protection Agency regulations
require:
•	MSW landfills to report their
waste capacity to the
appropriate state agencies.
•	Large MSW landfills to obtain
what are commonly called
"Title V permits" from their state
air permitting authorities.
•	Large MSW landfills to calculate
whether their emissions will
exceed regulatory levels and, if
so, install emissions controls.
•	States to submit plans to the
EPA requesting approval to
implement the EPA's MSW
landfill air emissions regulations
for existing MSW landfills, as
well as annual progress reports.
•	The EPA to approve state plans
or implement a federal plan.
This report addresses the
following:
•	Improving air quality.
This project addresses these top
EPA management challenges:
•	Complying with internal control
(data quality).
•	Overseeing states implementing
EPA programs.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
EPA Needs to Improve Oversight of How States
Implement Air Emissions Regulations for Municipal
Solid Waste Landfills
What We Found
We identified 12 active MSW landfills in the two states
we audited, Georgia and Texas, that could be operating
without the required Title V permits. The Georgia and
Texas state agencies responsible for issuing Title V
permits to MSW landfills did not always obtain the data
needed to verify whether the landfills required a Title V
permit and whether landfill emissions exceeded
allowable levels. In four instances, the regulatory
requirements were misinterpreted.
The EPA did not identify deficiencies in how Georgia and Texas implemented Clean
Air Act regulations to control air emissions from MSW landfills. For example,
to oversee state implementation of the 1996 regulations to address emissions from
existing MSW landfills, EPA Regions 4 and 6 should have—but did not—verify
whether Georgia and Texas submitted (1) complete state plans requesting approval
to implement these regulations and (2) the required annual progress reports. EPA
review of these documents is necessary to provide assurance that states have an
adequate plan for and are effectively implementing and enforcing MSW landfill
emissions regulations in accordance with federal requirements.
Wthout effective state implementation and EPA oversight of Clean Air Act regulations
for MSW landfills, these landfills could operate for years without required emissions
controls. As a result, MSW landfills could emit more air pollutants than allowed under
a Title V permit, and state efforts to meet the EPA's air quality standards for ozone
and fine particulate matter could be hindered. The EPA revised its Clean Air Act
regulations for MSW landfills in 2016 and requested that states submit new plans for
existing MSW landfills. Implementation of the revised regulations provides the EPA
with an opportunity to verify that the new plans are complete, annual progress reports
are submitted, and proper oversight is conducted.
Recommendations and Planned Agency Corrective Actions
We recommend that the regional administrators for Regions 4 and 6 require that
Georgia and Texas determine whether the MSW landfills identified in this report need
to obtain Title V permits and install emissions controls. We also recommend that the
EPA develop guidance for Clean Air Act MSW-landfill requirements that addresses
the review and oversight of the Title V permitting process, the approval of state plans,
the review of annual progress reports, and the periodic review of implementation and
enforcement. We consider four of our seven recommendations resolved with
corrective actions pending. The remaining three are unresolved.
Effective EPA oversight
of state implementation
of landfill air emissions
requirements helps
achieve air quality,
public health, and
environmental goals set
by the Clean Air Act.
List of OIG reports.

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