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The guidance also states that a minimum of ten sources should be used in developing a default <br /> value(use of fewer sources results in unreliable values).However several of the AP-42 defaults <br /> were developed from many fewer samples and sometimes just one sample.In view of the high <br /> variability observed between landfill test results,it is recommended that U.S.EPA carefully <br /> review its practices in developing AP-42 defaults with fewer than ten samples.At a minimum, <br /> defaults derived from limited data should be clearly identified and users cautioned as to their <br /> questionable reliability. <br /> LFG Constituent Declines <br /> Large,long term declines in LFG HAP values were documented in the August 1999 WIAC <br /> report.This report focused on four active and two closed landfills in Southern California.The <br /> decline at the active landfills was concurrent with implementation of waste-screening programs <br /> that prevented the disposal of incidental amounts of hazardous wastes present in the municipal <br /> solid waste stream starting in the early 1980's.U.S.EPA's Resource Conservation and Recovery <br /> Act(RCRA)rules for MSW landfills,implemented starting October 9, 1991 (40 CFR 258.20) <br /> also began requiring such exclusion programs on a nationwide basis.Additionally,the U.S.EPA <br /> established Subtitle C requirements per the 1984 RCRA amendments that set minimum treatment <br /> standards for listed wastes.This program ensured that the treatment residuals were placed in <br /> Subtitle C landfills.The combination of these programs likely reduced or eliminated incidental <br /> hazardous waste disposal in active MSW landfills. <br /> An attempt was made to determine whether a similar long term decline could be detected at other <br /> active landfills represented in the AP-42 database.A comparison was made of those sites that <br /> were reported by both EPA and WIAC.However it was found that many of the AP-42 landfills <br /> had coded names.The only active sites identifiably the same were those already'reported in the <br /> August 1999 report.It is recommended that U.S.EPA identify the coded AP-42 landfills so that a <br /> meaningful comparison could be made with the WIAC results. <br /> The LFG HAP decline for the two closed landfills in the August 1999 report would be unrelated <br /> to improved hazardous waste management practices.However the anaerobic decomposition <br /> processes at these sites are likely to have brought about such declines through one or more <br /> mechanism.HAP compounds will tend to volatilize into newly generated anaerobic gases;the <br /> .gases together with the trace constituents will ultimately exit the landfill,removing the HAP <br /> compounds.Additionally,anaerobic processes may destroy or transform some HAP compounds. <br /> Another factor to consider in the decline of HAP compounds is the effect of improved laboratory <br /> methodologies in recent years.Areas of improvement include utilization of more sophisticated <br /> equipment and adoption of standardized procedures for all analytical aspects.Some of the <br /> improved procedures include sample container preparation,instrument calibration,and quality <br /> assurance acceptance criteria. <br /> Equipment and procedure improvements reduce the scatter of data,increase data reliability, <br /> minimize compound misidentifications,and lower detection limits.Detection limits are especially <br /> important since several of the AP-42 compounds have few or no detections;improved detection <br /> limits would tend to lower the calculated AP-42 defaults.One laboratory submitting data for this <br /> report indicated that detection limits were more than halved in the last five years. <br /> Urban Air Toxics Strategy <br /> The U.S.EPA used AP-42 defaults for the recently completed Urban Air Toxics(UAT)Strategy. <br /> A review of the UAT findings based on the newer WIAC results is presented in Table 3.For all <br /> compounds detected in LFG,municipal landfills dropped in rank among industrial sources.The <br /> 6 <br />