Agency
Department of Environmental Quality
 
Board
Virginia Waste Management Board
 
Guidance Document Change: Elevated temperature landfill (ETLF) conditions have recently occurred at multiple permitted municipal solid waste (or sanitary) landfills in Virginia. These landfills are performing required air and solid waste regulatory monitoring, but some did not respond to impending ETLF conditions when detected. This has resulted in noxious odors, unpermitted discharges of leachate to surface water, and skyrocketing costs beyond available financial assurance. Therefore, DEQ is taking a unified multi-media approach to address landfills with rising temperatures to ensure that ETLF conditions are recognized and addressed. The purpose of this guidance is to ensure early detection of ETLFs through proactive monitoring, to ensure appropriate financial assurance from owner/operators, and to establish appropriate corrective actions to avoid additional negative environmental impacts in Virginia.
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8/12/26  9:28 pm
Commenter: Laura Helander, City of Bristol, Virginia

Leachate notifications and sampling locations
 

IV.B.4 and V.B.4

Leachate Notifications (referencing 9VAC20-81-530.C.3)

Comment:  The requirement to notify DEQ within 24 hours and then follow up with a five-day letter is an unnecessary burden, duplicative for some permit holders, and does not apply to landfills that discharge into out-of-state waters.  The City of Bristol, Virginia discharges directly to a POTW in another state (Tennessee).  The out-of-state POTW has its own requirements for reporting non-compliance.  Non-compliance does not affect Virginia state waters; therefore, this clause is not applicable for direct discharges to out-of-state POTW’s.

In addition, there is no notification section, or reference to previous notification sections, for Category 3 landfills.

 

V.B.2 (Sampling Locations)

Comment: The process of identifying which locations to test should take into account the landfill's specific location.  Sampling every well in a small landfill may not provide useful information and could be an onerous testing plan (including expensive).  Larger landfills will likely benefit from localized testing to determine where the high temperature and reactions are occurring.  Sampling should not be a one-size-fits-all solution for ETLFs.

 

 

CommentID: 240818