SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin entitled EPA Seeks Feedback On Inactive Surface Impoundments at Inactive Electric Utilities summarizes the EPA’s request for comments and information pertaining to inactive impoundments at inactive facilities.
Operators and owners who may be affected by forthcoming decisions around inactive CCR surface impoundments include electric utilities and independent power producers who generate CCR within the North American Industry Classification System (NAICS) code 221112. Though the EPA states “other types of entities … could also be regulated” and advises those wanting to confirm if the regulation applies to them to read the applicability criteria and comment. Landowners with a legacy surface impoundment on their property purchased from a utility will want to review the proposed definitions closely.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.
Visit our website for more information.
Per- and poly-fluoroalkyl substances (PFAS) are receiving increasing attention from regulators and the media. Within this large group of compounds, much of the focus has been on two long-chain compounds that are non-biodegradable in the environment: PFOS (perfluorooctane sulfonate) and PFOA (perfluorooctanoic acid). Long detected in most people’s bodies, research now shows how “forever chemicals” like PFAS accumulate and can take years to leave. They persist even when excreted through urine. Scientists have even tracked them in biosolids and leafy greens like kale. Recent studies have linked widely used PFAS, including the varieties called PFOA and PFOS, to reduced immune response and cancer. PFAS have been used in coatings for textiles, paper products, cookware, to create some firefighting foams and in many other applications.
Testing of large public water systems across the country in 2013 through 2015 found PFAS detected in approximately 4 percent of the water systems, with concentrations above the USEPA drinking water health advisory level (70 parts per trillion) in approximately 1 percent (from ITRC Fact Sheet.) Sources of higher concentrations have included industrial sites and locations were aqueous film-forming foam (AFFF) containing PFAS has been repeatedly used for fire fighting or training.
Source identification is more difficult for more widespread low-level PFAS levels. For example, in Madison, Wisconsin, PFAS have been detected in 14 of 23 municipal water supply wells, but the detected concentrations were below the USEPA’s health advisory levels for PFOA and PFOS. A study of potential PFAS sources near two of the Madison wells identified factories, fire stations, landfills, and sludge from sewage treatment plants as possible sources, but did not identify a specific source.
With the EPA positioned to take serious action on PFAS in late 2019 and 2020, regulators in many states have already started to implement their own measures, while state and federal courts are beginning to address legal issues surrounding this emerging contaminant. State actions have resulted in a variety of state groundwater standards for specific PFAS compounds, including some that are significantly lower than the USEPA advisory levels. These changes mean new potential liabilities and consequences for organizations that manufacture, use, or sell PFAS or PFAS-containing products, and also for the current owners of properties affected by historic PFAS use.
Questions for manufacturers, property owners, and property purchasers include:
If remediation is required, a number of established options to remove PFAS from contaminated soil and groundwater are available, including activated carbon, ion exchange or high-pressure membrane systems. On-site treatment options, including the management of reject streams where applicable, are also available.
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Use these resources to explore more about PFAS each is linked to helpful articles and information.
The Pennsylvania Department of Environmental Protection (DEP), Bureau of Waste Management, has awarded SCS Engineers (SCS) a contract to provide recycling and organics management technical assistance to local governments throughout the state. Brent Dieleman, SCS’s Project Manager, has years of experience administering these types of programs for the Solid Waste Association of North America.
Pennsylvania ratified “Act 101” in 1988 to manage waste and promote recycling across the Commonwealth. The DEP developed the Recycling Technical Assistance Training Program to help local governments comply with Act 101 by improving and expanding their collection and diversion programs. SCS will help administer and provide technical assistance to this Program. The comprehensive support provides for curbside and drop-off recycling programs, solid waste planning, public education, materials processing, equipment, technical training, environmental protection programs, and organics management.
Additionally, local governments can apply for technical assistance, up to $7,500 per applicant, to help expand and improve their recycling and organics management systems. SCS will work with applicants to assess their needs and refine the scope of their project. Once DEP approves a technical assistance project, SCS will then provide specialized, tailored training to each recipient.
SCS will help each grant recipient address the unique issues and challenges facing their program including, composting, collections, incentive-based programs such as pay-as-you-throw, and siting of new facilities. SCS anticipates providing technical assistance for up to 30 local governments annually.
DEP is tasking SCS with helping them find ways to further promote the Program across the Commonwealth and enable local governments to benefit from it. SCS anticipates presenting the initiative to local landfill owners and operators at a seminar in Harrisburg, Pennsylvania on June 9, 2017.
“In recent years Pennsylvanians have recycled nearly 17 million tons of waste, which removed almost 16 million tons of carbon dioxide emissions from the air. That is equivalent to saving the electricity used in 2.18 million American homes per year or taking 3.34 million passenger vehicles off the road for one year,” said Brent Dieleman. “We’re facilitating the DEP to help local governments efficiently expand their recycling programs.”