From The Atlantic, Family Section
I, too, had a more-than-passing interest in the garbage truck as a kid; with palpable residual excitement, I can remember peeking through the window shutters of my parents’ front room to watch the vaguely menacing robotic arm jut out, snatch our garbage can, and dangle the can upside down over its back while the trash tumbled out. Why generations of kids have been so transfixed by the trash pickup, though, remains something of a mystery. So I asked parents, kids, child-development experts, waste-management professionals, and even the creator of a kids’ show about an anthropomorphized garbage truck for their insights. Together, we made our way—more aptly, lurched and rumbled our way—toward a unifying theory of why kids are so wild about garbage trucks.
Author ASHLEY FETTERS talks to several experts and the two foremost authorities—kids and garbage-truck drivers. Naturally, we never lost our fascination with the men and women in our industry.
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 http://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin summarizes the 2020 USEPA Adds 172 PFAS Chemicals to EPCRA TRI Reporting Program. The new PFAS rule went into effect on June 22, 2020. However, the rule requires PFAS to be included in TRI reports submitted for all 2020 calendar year activity (i.e., January 1 through December 31). The deadline for submitting the 2020 TRI reports is July 1, 2021.
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.
Contact http://www.scsengineers.com for an Environmental Engineer near you.
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.
Our most recent Bulletin summarizes the 2020 Virginia State Plan for New Landfill EG approved by the USEPA on June 23, 2020.
The Environmental Protection Agency (EPA) approved a Clean Air Act (CAA) section 111(d) plan submitted by the Virginia Department of Environmental Quality (VADEQ). This plan was submitted to fulfill the requirements of the CAA and in response to EPA’s promulgation of Emissions Guidelines and Compliance Times for municipal solid waste (MSW) landfills.
The Virginia plan establishes emission limits for existing MSW landfills and provides for the implementation and enforcement of those limits. Highlights of the plan are explained in a newly published SCS Technical Bulletin.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed.
On March 26, the U.S. Environmental Protection Agency (USEPA) finalized amendments to the 2003 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste Landfills. The NESHAP rules affect air permits and landfill gas system operating requirements for most active landfills. Read the Technical Bulletin here.
Some permittees welcome the revised wellhead operational standards, but other changes including additional monitoring requirements for wells operating at higher temperatures, and correction and clarification of Startup, Shutdown, and Malfunction (SSM) requirements are creating confusion. Landfill owners have an 18-month phase-in period before full compliance with the NESHAP requirements, so now is the time to unravel the confusing language between NESHAP rules and existing New Source Performance Standards (NSPS) rules (Subpart WWW and Subpart XXX).
SCS Engineers and SWANA are presenting a series of webinars and resources to help landfill owners and operators untangle the confusing permit phraseologies and implications created when state agencies with air permitting authority incorporate the NESHAP requirements into Title V operating permit renewals and construction permits.
Tune in for advice on Wednesday, June 24, 3:40 PM – 4:15 PM:
SWANAPalooza 2020 Virtual Conference — Navigating the Maze of Federal Air Quality Regulations for Landfills with Pat Sullivan. Pat and other presenters will discuss the EPA’s landfill regulations, including NSPS, NESHAP, and Emission Guidelines.
Tune in earlier for other key presentations including:
It’s important to make sure we recycle right, not just recycle often! It’s exciting to see all the new products made from the bags and the technology used to sort them – but how individuals’ recycle does matter.
It doesn’t take many plastic bags to get wrapped up in the recycling equipment, causing the equipment to work inefficiently and forcing it to shut down multiple times every day. The facility staff must enter or climb on the screening equipment to cut away bags as in this video.
If you use a plastic bag to collect your recyclables, empty the recyclables into your recycle bin and reuse the bag or recycle it at your grocery or retail store. Don’t mix plastic bottles with plastic bags – that’s what causes safety and efficiency problems in the first place.
Most grocery stores and retail stores such as Walmart, Target, and Lowes have recycling bins for this type of plastic. If you are not reusing the bags, take them to a drop off location, which is probably the same store where you got them.
Find the stores nearest you by visiting this site – a list of all the store drop-off locations in your zip code.
More than just your plastic retail bags can often be recycled, but it’s good to check with your drop-off to see what’s accepted. Examples of what often can be recycled include:
Now, if you are on the other end of the consumer chain and looking to provide a program for your school, community, or solid waste planning area, there is no need to start from scratch! Many other such entities have already developed successful recycling programs and are more than happy to share what they have done. Additionally, end-users in need of this material are also ready and willing to assist with setting up programs, such as the one found here. Plastics wraps, bags, and film may not be going away any time soon, but as long as they are here, there is great reuse for them!
About the Author: Christine Collier is an SCS Senior Project Professional in Des Moines, Iowa. She has over 18 years of experience in the Iowa solid waste industry. She has spent most of her career as both a client and project manager working directly with clients to ensure their projects were being completed on schedule and within budget. Her focus has been on working as a member of the client’s team as an advocate for their best interest. Through her career, she has become an expert in Iowa’s solid waste regulations and compliance requirements. She has BS and MS degrees from Iowa State University in Civil Engineering with an environmental emphasis and is a licensed Iowa Professional Engineer.
Providing a safe work environment is always essential, but never more so than now. Meeting PSM/RMP compliance deadlines, providing ammonia refrigeration operator training, and maintaining critical safety systems are key components in a safe work environment for facility employees.
Safety systems, such as ammonia leak detection systems, must remain operational as required under the following regulatory criteria:
• OSHA 29 CFR 5189, Process Safety Management (PSM) Section (j)(2)(C) Mechanical Integrity
• EPA’s 40 CFR Part 68, Risk Management Program (RMP) Part 68.73
• EPA General Duty Clause
• RAGAGEP – IIAR Standard 6
These criteria require companies to comply with the manufacturer’s recommendations for maintenance and calibration of ammonia detection systems. Calibrating ammonia sensors on a frequency determined in these same recommendations keeps your business compliant. We all know that compliance is non-negotiable as the ammonia detection system is a life-safety device.
Dedicating itself to providing a variety of online training and virtual meetings, the SCS Tracer Environmental team ensures your systems meet all regulatory obligations. When site visits are necessary; our teams and your facility members use a CDC-based safety protocol meeting state and local requirements, and facility requirements.
For assistance with ammonia sensor calibrations, please contact Mark Carlyle.
On-Demand Webinar at A&WMA Virtual Conference
The U.S. Environmental Protection Agency (EPA) has created confusion with its most recent versions of the MSW landfill New Source Performance Standards (NSPS) and Emission Guidelines (EG) [40 Code of Federal Regulations (CFR) Part 60, Subparts XXX and Cf], which were promulgated in August 2016. The NSPS XXX and EG Cf rules do not give clear on and off-ramps from the old NSPS Subpart WWW and EG Subpart Cc rules and have various inconsistent and overlapping requirements. EPA made matters worse by not updating the MSW landfill National Emission Standards for Hazardous Air Pollutants (NESHAPs), 40 CFR Part 63 Subpart AAAA rule at the same time. This created a situation where both the old and new rules could apply simultaneously, even though the new rules were supposed to replace the old rules (with conflicting requirements).
This and other issues forced the industry to petition EPA for relief, and the industry obtained a temporary stay and then a commitment to reconsider the rules. Concurrently, EPA informally agreed not to push forward with approving state plans for the EG under Cf, which gave the industry hope that EPA could fix the rules before most landfills became subject to the new rules via approved state plans. However, some states sued EPA over this delay, and EPA lost. As such, EPA was forced by the courts to begin approving the state plans as well as issue a federal plan for the EG (Subpart OOO), for which a draft rule was published in August 2019 and a final rule is pending.
Also, before they planned to reconsider Subparts XXX/Cf, EPA decided to update the NESHAP rule, including a risk and technology review (RTR). While doing this, EPA also tried to resolve some of the Subpart XXX/Cf issues using the NESHAPs rule as well as add some new requirements not included in the NSPS XXX and EG Cf rules. However, the draft NESHAPs rule demonstrated that EPA had only created more confusion and uncertainty.
The solid waste industry commented on the Subpart AAAA rule and is waiting for EPA to issue it. EPA says the reconsideration of XXX/Cf will not be considered until 2021 or 2022.
Currently, landfill owners and operators remain in a state of limbo. Some sites are complying with Subpart XXX and dealing with the duplicate requirements from Subpart WWW and other issues. Several states have approved Cf EG rules, so landfills in those states must begin to comply with those state rules. Several other states have proposed state plan approvals and could see approved EG rules issued soon. When EPA issues the federal plan for the EG, all of the remaining landfills in states without approved state plans will have to start to comply. This will put all NSPS/EG-applicable landfills into the same boat with the existing Subpart XXX sites with all of the problems that will bring.
The Air & Waste Management Association with SCS Engineers presents on-demand sessions include an update on the status of each of the regulations identified here, a description of the remaining areas of uncertainty and confusion, and a summary of the strategy for compliance in use by landfills during this period of limbo.
Matt Brokaw, P.E. joins the SCS Engineers new office at 3801 Lake Boone Trail, Suite 430, Raleigh, NC 27607, Tel: +1-919-662-3015
SCS Engineers, a top-tier ENR environmental consulting and construction firm, opened a larger office in Raleigh, North Carolina, in late May. The move centralizes the team closer to their clients’ sites to provide full-services. The new office accommodates new team members, including Matt Brokaw. Matt joins the SCS professionals who provide environmental services for solid waste management for the benefit of municipal and private landfills, public works, and recycling.
As a Senior Project Professional, Matt is responsible for the engineering and design of environmental solutions, with a primary focus in solid waste, stormwater management and planning, and erosion and sediment control critical to permitting compliant facilities and ultimately protecting natural resources. Extending the life of a landfill and adding airspace is often critical for the communities SCS clients serve.
The new SCS Raleigh location supports the growing demand for full-service environmental solutions supported by a mix of professionals. As specialized teams, they can help reduce greenhouse gas emissions, capture landfill gases, create renewable energy from by-products, and optimize utilities and businesses using environmental practices that are economically feasible. The firm specializes in permitting for and meeting comprehensive clean air, water, and soil goals. It provides a range of services such as PFAS treatment, solid waste master planning, landfill technology, risk management, groundwater monitoring, pre-closure and landfill closures, and Brownfields remediation.
About SCS Engineers
SCS Engineers’ environmental solutions and technology are a direct result of our experience and dedication to solid waste management and other industries responsible for safeguarding the environment. For more information about SCS, please visit our website at www.scsengineers.com/, contact email@example.com, follow us on your preferred social media, or watch our 50th Anniversary video.
CERLCA Jurisdiction and PRP Definition
A recent Meyers | Nave publication discusses the Supreme Court’s April 20, 2020 decision in Atlantic Richfield Co. v. Christian. The firm suggests the decision adds another layer of complexity to the Comprehensive Environmental Response, Compensation, and Liability Act – CERCLA, liability issue. The decision opens the door for state courts to hear claims that challenge EPA-defined approved clean-ups and has the potential to expand the “potentially responsible party” – PRP class for current “owners” of a “facility.”
The Court’s decision introduces new considerations into CERCLA liability analysis and settlement strategy. The Court’s holding will have many immediate ramifications, including the following:
Clean Water Act Developments
In April, the courts and federal agencies announced major developments significantly affecting regulation under the Clean Water Act – CWA and how the CWA may be applied in the future.
Each of these developments could have far-reaching implications for regulations under the CWA. Assuming the 2020 Rule withstands legal challenges, it is seen as favorable for industry and other regulated entities, while the two judicial decisions are perceived as problematic for such entities. Davis Graham & Stubbs describes each development in more detail in the firm’s recently published article.
MATS Supplemental Cost Finding and Clean Air Act RTR
On April 16, 2020, the U.S. Environmental Protection Agency (EPA) finalized the 2016 Supplemental Cost Finding for the Mercury and Air Toxics Standards – MATS, for coal- and oil-fired power plants, consistent with a 2015 U.S. Supreme Court decision. The agency also completed the Clean Air Act-required residual risk and technology review – RTR, for MATS. According to the EPA power plants are already complying with the standards that limit emissions of mercury and other hazardous air pollutants (HAPs), and this final action leaves those emission limits in place and unchanged.
However, with this final action, EPA is not removing coal- and oil-fired power plants from the list of affected source categories for regulation under section 112 of the Clean Air Act, consistent with existing case law. Those power plants remain subject to and must comply with the mercury emissions standards of the MATS rule, which remains fully in effect notwithstanding the revised cost-benefit analysis.
In addition, EPA has completed the required RTR for MATS and determined no changes to the rule are needed to further reduce residual risk. The RTR satisfies the statutory requirements set out by Congress in the Clean Air Act. More information is available on EPA’s Mercury and Air Toxics Standards website.
Proposal to Retain NAAQS for Particulate Matter
On April 14, 2020, the U.S. Environmental Protection Agency – EPA announced its proposal to retain, without changes, the National Ambient Air Quality Standards – NAAQS for particulate matter (PM) including both fine particles (PM2.5) and coarse particles (PM10).
According to the EPA because of Clean Air Act programs and efforts by state, local and tribal governments, as well as technological improvements, average PM2.5 concentrations in the U.S. fell by 39 percent between 2000 and 2018 while average PM10 concentrations fell by 31 percent during the same period.
EPA states it is following the principles established to streamline the NAAQS review process and to fulfill the statutory responsibility to complete the NAAQS review within a 5-year timeframe. More information about the rule can be found at EPA’s: National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM) Pollution website.
EPA will accept public comment for 60 days after the proposed standards are published in the Federal Register. EPA plans to issue the final standards by the end of 2020.
U.S. Greenhouse Gas Emissions and Sinks Inventory Announcement
The Environmental Protection Agency’s annual report, “Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2018,” provides a comprehensive look at U.S. emissions and removals by source, economic sector, and greenhouse gas – GHG. The gases covered by this inventory include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride. The inventory also calculates carbon dioxide emissions that are removed from the atmosphere by “sinks,” e.g., through the uptake of carbon and storage in forests, vegetation, and soils.
On April 13, 2020, the EPA’s comprehensive annual report on nationwide GHG emissions released to the public. It shows that since 2005, national GHG emissions have fallen by 10%, and power sector emissions have fallen by 27%.
“While there was a small rise in emissions due to weather and increased energy demand from the prior year in this report, based on preliminary data, we expect next year’s report to show that the long-term downward trend will continue,” said EPA Administrator Andrew Wheeler.
According to the announcement, annual trends are responsive to weather variability and economic conditions. Year-over-year, national GHG emissions were 3% higher in 2018 than the prior year, due to multiple factors, including increased energy consumption from greater heating and cooling needs due to a colder winter and hotter summer in 2018 compared to 2017.
According to environmental and research groups, driving the drop’s long-term downward trend is chiefly due to a shift away from coal power generation. The 2019 drop was driven by a nearly 10 percent fall in emissions from the power sector, the biggest decline in decades [Rhodium Climate Service]. Utilities are closing coal plants in favor of cheaper natural gas and renewable energy.
Emissions from industry rose slightly last year, and are now greater than those from coal-fired power plants, most driven by a strong economy. Emissions from buildings were up, and emissions from other sectors of the economy collectively grew by more. The shift to lower-carbon energy is largely restricted to the electricity sector, and in order to meet international and state goals, state policies continue to target other sectors that collectively make up a majority of U.S. emissions.
More information is available at EPA’s website Inventory of U.S. Greenhouse Gas Emissions and Sinks.
For more information about potential impacts to waste, energy, or manufacturing please contact your nearest SCS Engineer’s office or your Project Manager.
In this Waste Today article, Sam Cooke discusses the factors, treatment options, analytical methods, and identifying PFAS sources to most effectively reduce the concentrations of ammonia and PFAS in landfill leachate.
Reducing these concentrations help meet discharge permit requirements for direct discharge of treated leachate to surface waters and to meet publicly owned treatment works (POTW) discharge permit standards.
Sam points out that accomplishing ammonia and PFAS reduction with established wastewater treatment technologies works, but the right treatment depends on each site’s specific parameters. He suggests conducting bench-scale and pilot-scale testing for any feasible nitrogen removal or treatment system. Testing the wastewater helps to identify any changes in the concentration of nitrogen compounds. Thus, necessary changes to the treatment processes, such as additional aeration or chemical additions are easier to identify and less costly to implement.
About the Author: Mr. Cooke, PE, CEM, MBA, is a Vice President and our expert on Industrial Waste Pretreatment. He has nearly three decades of professional and project management experience in engineering with a concentration in environmental and energy engineering. Mr. Cooke works within SCS’s Liquids Management initiative to provide services to our clients nationwide.