NSPE Urges EPA to Require PEs for Landfill Audits

November/December 2015

NSPE Urges EPA to Require PEs for Landfill Audits

On September 14, NSPE submitted a public comment to the Environmental Protection Agency commending the agency for proposing additional safety measures requiring a PE to prepare site-specific gas collection and control system plans as part of the proposed rule Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills.

In public comments on the proposed rule, NSPE also asserted that the landfill auditing process is best performed by licensed professional engineers. After all, as acknowledged in this very proposed rule, licensed professional engineers are uniquely qualified to perform the underlying compliance work. Therefore, it makes the most sense that the professional best qualified to review such work would also be a licensed professional engineer.

The EPA is considering allowing self-audits of such facilities instead of requiring independent third-party audits. NSPE strongly encouraged EPA to maintain the current system of independent third-party audits, a proven method that works and provides the best protection of the public health, safety, and welfare. However, should the EPA allow a self-auditing process, NSPE stated that the report must be prepared by a licensed professional engineer.