EPA Requires Reporting on Releases and Other Waste Management of Certain PFAS, Including PFBS
As part of EPA’s Strategic Roadmap, the Agency announced the automatic addition of four per- and polyfluoroalkyl substances (PFAS) to the Toxics Release Inventory (TRI) list.
As of January 1, 2022, facilities that are subject to reporting requirements for these chemicals should start tracking their activities involving these PFAS as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. Reporting forms for these PFAS will be due to EPA by July 1, 2023, for the calendar year 2022 data.
In April 2021:
EPA previously updated the Code of Federal Regulations with PFAS that were added to the TRI on January 1, 2021, under section 7321(c) of the NDAA and regulated by an existing significant new use rule (SNUR) under the Toxic Substances Control Act (see 40 CFR 721.10536).
In addition to continuing to add PFAS to the TRI, the EPA will soon announce a series of PFAS test orders requiring PFAS manufacturers to provide the Agency with toxicity data and information on PFAS.
If you have questions or concerns about reporting requirements, contact one of our environmental chemistry – hazardous materials/waste professionals at .
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At SCS Engineers, you’re empowered to use your skill, experience, and energy to make a difference every day. As an employee-owned engineering consulting and contracting firm, we’re driven by a purpose to protect the air, water, and soil. We’ve been at the forefront of sustainable environmental solutions for more than 50 years.
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SCS Engineers is an EOE/V/D Employer
Become one of the engineers, consultants, scientists, and technicians that help private and public entities run cleaner and more efficiently. A very rewarding place to have a career!
The Fabricated Geomembrane Institute – FGI, discusses allowable leakage rates for industry. We strive for zero leakage and it is possible – this mix of regulators and practitioners including Neil Nowak of SCS Engineers discuss how to achieve it.
Click here to start the video.
The promulgation of 40 CFR 62 Subpart OOO (EG plan), effective since June 21, 2021, impacted all MSW landfills operated under NSPS subpart WWW. One of the major changes of this rule is the requirement to monitor all cover penetrations during quarterly methane surface emission monitoring (SEM). All components that are part of the landfill gas collection system and any other object that completely passes through the landfill cover are considered cover penetrations.
As landfill and landfill gas practitioners, we suggest that advanced planning can save you time and effort. As landfills face short 10-day correction periods, coupled with supply chain and labor shortages, planning can make operations and compliance more efficient. We present a few scenarios and suggestions here.
You’ll need to record any reading greater than 500 ppm above background as an exceedance location during monitoring. These require taking corrective actions such as cover maintenance or landfill gas wellfield adjustments, along with monitoring the exceedant locations again within 10-days of your initial monitoring. If 10-day monitoring still shows methane concentrations greater than 500 ppm, you’ll need additional corrective actions and to monitor the location once more within 10-days of the second exceedance.
Once the location(s) shows methane concentrations less than 500 ppm, it is mandatory to monitor these locations again one month from the very first reading showing the exceedance. If a location shows methane concentration greater than 500 ppm for three occasions in one quarter, the addition of a collection device, other improvements to the collection system, or a request for an alternative remedy and timeline is required. Therefore, implementing appropriate corrective action within the specified timeframe is critical to avoid expensive GCCS expansions or NOVs.
Gas well, well boots, leachate risers, below and above-grade pipe transition, condensate sumps, and valve vaults are some of the common exceedant penetration locations. Implementing corrective action at these penetrations within the given timeframe is a challenging ordeal for landfill operators. Corrective action can vary depending upon several factors: the methane concentration observed during initial monitoring, the location of the penetration, cover type (geomembrane capped vs. soil capped), material availability, and resources available to perform the work.
Corrective actions have varying material and effort requirements; one solution cannot fit all challenges. The most common corrective actions include applying expanding foam, soil mounding, excavation, clean dirt fill or bentonite fill, well boot repairs, installing a prefabricated well boot seal, and installing a vacuum line for emission control. We recommend before starting your monitoring operators consider the following factors:
Develop an educated estimate for the number of expected exceedant penetrations from the landfill sections that historically show cover exceedances or are in areas with problematic operating conditions. Using the readings and data collected over time makes identifying these areas much easier.
Decide the type of corrective action to implement based on your cover type in those expected exceedance locations.
Procure corrective action materials such as bentonite, geomembrane for boot fabrication matching permitted cap material, or prefabricated seals before you need them.
Check the availability of contractors for liner or well boot repairs, and their response time, before you need them.
Surface emissions vary based on the operating conditions; therefore, it is common to see a variable number of exceedances from one quarterly monitoring event to the next. At one of our sites that had no surface exceedances observed during the previous quarterly SEM event, multiple penetrations observed methane concentration greater than 500 ppm during the following quarterly event. One section of the landfill with a soil cap observed methane concentrations up to 16,000 ppm. The geomembrane capped section observed penetration concentrations of up to 8,000 ppm methane. We implemented various corrective actions to bring these exceedant locations to compliance.
In the soil-capped section, we implemented bentonite plugs, prefabricated seals, and site fabricated geomembrane seals depending upon the observed methane concentration, exceedant location, and material availability. Pre-planning and procuring material ahead of time proved to be very helpful.
For each of these corrective actions, we opened an area about 2-ft deep and 10-ft x 10-ft. For bentonite corrective action, about a 9-inch thick bentonite slurry was filled, extending about 5-ft on each side of penetration and then filled with clean dirt.
Prefabricated seals that come in standard sizes as a slip-on for penetrations and site-fabricated geomembrane seals also covered at least a 5-ft x 5-ft area around each penetration. The sleeves at each penetration were left at least 6-inch over the ground surface after filling the excavated section with clean dirt.
In the geomembrane-capped section, we choose to use well boot repairs using geomembrane. Our task was to identify the type of geomembrane used in the cap, procure the geomembrane, identify and schedule the contractor, and install well boots in each exceeding penetration location within the 10-day timeframe. After the well boot fabrication and installation, we needed to carefully reconnect the existing drainage layer.
Implementing these corrective actions can get expensive; prefabricated seals can cost up to $300 per penetration, excluding installation. Material and contractor’s availabilities are also a significant challenge. While implementing these corrective actions, additional unforeseen challenges can arise as well. Planning ahead and having the material on site is very important for landfill operators to keep the landfill under compliance.
About the Authors:
Shrawan Singh, Ph.D., PE, is a Senior Project Professional. Stephen Descher is a Senior Project Professional. You can reach both at SCS Engineers.
If you thrive in a friendly, collaborative, and client-focused company, SCS Engineers is the place for you. We’re looking for field technicians to work collaboratively on our Field Services teams nationwide. Use our job search to find your desired location. Specific information is posted for each open position.
Under general supervision, our technicians operate, monitor, and maintain gas migration control and recovery systems, including gas well monitoring and adjustment, troubleshooting, and system repairs. Be part of a team working for the good of our clients, communities, and the environment.
Commercial, industrial, and multi-family buildings about to undergo major renovations commonly contain hazardous materials, whether asbestos, lead, mercury-containing devices, Freon, PCBs, or others. They’re present in various building materials, painted surface coatings, mechanical equipment, or other items utilized for property operation.
Examples include, but are not limited to, old dial thermostats, fireproofing, floor coverings, adhesives, paints/varnishes, smoke detectors, and fluorescent lights. If left intact during renovations, they can create inhalation, ingestion, and dermal hazards that pose a significant risk to human health and the environment. These materials must be identified and managed properly to mitigate accidental human exposure and environmental risk; stay in good graces with regulators, and prevent project delays.
The safest and most effective approach is designing and executing a good abatement plan where highly skilled, licensed workers come in and properly remove potential offenders before the renovation begins.
Abatement is an involved process commanding adherence to tightly regulated protocol around securing materials, ensuring contaminants do not become airborne, properly containerizing and disposing of them in landfills permitted to accept these regulated wastes. It takes orchestration, with multiple trade contractors working in tandem, and ideally a third-party professional to oversee and streamline the entire process.
Full abatement is practical.
Mike Dustman, an SCS Engineers senior project manager who oversees environmental remediation jobs, recommends that property owners survey their buildings for the presence of hazardous materials before renovation begins and remove them, rather than remove some materials and entomb others—particularly for major overhauls.
“While a full, thorough abatement costs more upfront, it saves over the project span in both money and headaches. You will pay more to monitor and provide upkeep if you leave live building systems like plumbing and electricity entombed with asbestos or other hazardous materials. Leaving them in place can delay or complicate the renovation, or even impede ordinarily quick maintenance projects in the future,” Dustman says.
He illustrates using a scenario where asbestos-containing fireproofing left in exterior soffits holding the building’s roof drains caused expensive repairs later. A full asbestos containment must be set up when the drains leak to make a relatively simple plumbing repair. “To avoid situations like this, property owners should plan and budget to abate and remove all hazardous materials from their buildings fully,” Dustman says.
Suppose you have limited cleanup dollars, your resources for renovation shrink when involving abatement. Property owners without the upfront capital might limit the scope of their renovation at first. An initial survey helps determine where conducting abatement projects is necessary and where it is practical to leave materials in place while raising money to plan for a full abatement later.
Assessment and cleanup grant dollars may be available through U.S. Environmental Protection Agency (EPA) grants issued to local municipalities through Brownfield programs.
Planning for the future is key.
Prepare abatement design with thought to existing structural, mechanical, electrical, and plumbing designs that will either be retrofitted or use new building systems.
The design considers where those new systems will run, removing hazardous materials before installing new systems, preventing potential worker exposure and project delays. Contractors can safely and quickly access structural members, run new plumbing lines, or update interior finishes.
It’s on the property owner to identify potential hazardous building materials and equipment and inform renovation contractors of the presence and location of these materials preceding a renovation.
“The way we ensure and prove proper identification is by collecting bulk samples of suspect building materials and submitting them for lab analysis as part of the pre-renovation survey. The survey typically includes sampling building materials for asbestos, testing surface coatings for lead, and inventorying universal/hazardous waste items.
If the analysis does not detect the presence of harmful contaminants, you can safely proceed with your renovation project. However, if the survey identifies such contaminants, an abatement plan is necessary,” Dustman says.
A coordinated effort.
The first step is figuring out the abatement goal and the general contractor’s plans. And you must ask, what is the redesign of the building, its purpose, and the underlying material hazards?
Understanding the goals, what hazardous materials exist, and which materials will be impacted by a renovation allows for better awareness by all parties. It lowers the risk of accidental disturbance before and during removal, and it helps workers avoid disturbing hazardous materials until properly remediated.
The consultant that prepares the abatement design, the architect, engineers, and every party involved in the remodeling or renovation must be on the same page around such details as the scope of work, budget, and schedule. Transparency gives the abatement contractor and design consultant an understanding of what to clean before other trade contractors begin their work.
Preventing accidental exposure while work is in progress and upon project completion.
Worker safety is a common thread from start to finish. SCS performs daily air sampling throughout the removal process as third-party consultants to ensure the engineering controls are functioning as designed.
Enclosures are monitored during the renovation to confirm and document that no exposure is occurring outside of regulated work areas.
Once completing an area, Dustman’s team goes back in and visually inspects the work area, searching for remaining dust or debris. If the work area passes the visual inspection, they perform more air sampling to ensure safe reoccupation without respiratory protection.
In the case of a lead abatement project, the team conducts both air sampling and dust wipe clearance sampling. Dust wipe sampling is necessary since lead is a heavy elemental metal and quickly settles out of the ambient air and onto horizontal surfaces.
Once completing abatement, a close-out report confirms hazardous waste disposal to the appropriate regulatory enforcement agency. The report contains all air sampling and clearance data, with findings and conclusions supporting the data. “This report shows that you have executed and completed an effective abatement plan in compliance with federal, state, and local requirements,” Dustman says.
What if the building wasn’t, or couldn’t be, fully abated?
If hazardous materials remain, develop an operation and maintenance plan. It entails monitoring for future deterioration and meticulous recordkeeping documenting details such as type, location, and condition of remaining materials and removing or adding any materials. It’s a living document that is continually updated to determine when abatement is necessary and ensure that all details are readily available to move forward promptly.
“Identifying, removing, and properly disposing of hazardous materials found in your buildings before the renovation is an involved process with many steps. But every step counts to avoid occupant and worker exposures, accidental material disturbances, and to help complete your project on time,” Dustman says.
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Michael Dustman’s experience is in environmental project management, remedial design activities, building inspection, site assessments, and field training. He possesses an in-depth knowledge of relevant and applicable Federal, State, and local environmental laws and protocols. Mike has served as project manager for numerous local agencies and private clients, including the U.S. Environmental Protection Agency (EPA) Region 4 Superfund Technical Assessment and Response Team (START), City of Kansas City, Missouri Brownfields Office, and Commerce Tower Redevelopment Team. Mike’s expertise includes natural disaster emergency responses to major floods, hurricanes, and tornadoes. He is a certified asbestos project designer, management planner, building inspector, certified air sampling professional, and certified lead-based paint risk assessor.
Additional Resources
Brownfields and Voluntary Remediation
These days you see companies bending over backward to attract new hires. Puffy job descriptions, promises of success, big salaries, and benefits are everywhere. My advice is to learn about a company’s leaders — not yet retiring and not a young professional. What they talk about during interviews is often a good indication of what they are like and what they value. It has always helped guide me to work somewhere rewarding under the tutelage of remarkable people.
Mike McLaughlin is the Senior Vice President of Environmental Services for SCS Engineers and was once an SCS young professional. He graduated from law school in 1979 and continues to influence people and businesses every day, including many at SCS Engineers.
He is an environmental engineer with a law degree, and you’d be hard-pressed to find a more knowledgeable person in the field. You’d also be lucky to know him. He is as entertaining as thoughtful about finding practical solutions to environmental challenges and the things that matter.
Just reading the article A Special Place to Study Law makes me happy knowing I get to work with people like Mike, and you could too.
Since 1977, WomenShelter of Long Beach has helped thousands of families overcome the trauma caused by domestic abuse. WSLB assists victims and their children by providing safe housing and supportive services, including an emergency shelter, 24-hour crisis hotline, counseling, social services support, legal and health advocacy, and much more.
SCS Engineers adopted four families in our 5th year of sponsorship. We provide gift cards for each family and hope we can go back to shopping and wrapping gifts for them next year. We wish our families and all a happy holiday season!
More community support in 2021 here.
SCSeTools® – Developed by Landfill Gas Practitioners for Landfill Owners and Operators
The Birth of LFG Data Tracking
In the early 2000s tracking landfill gas data at facilities was anything but uniform, organized, or secure. The industry was using various methods to track data on paper forms and logbooks, then transferring it by hand into spreadsheets. Some of us used desktop database applications, but as the saying goes, necessity is the mother of invention.
From an SCS employee’s idea for demonstrating how to use landfill gas monitoring data to analyze and pinpoint system corrections, SCS DataServices® was born. In the span of several months, a team of SCS’s landfill engineers, field technicians, and technology gurus worked with client-needs to create a concept application visualizing collected landfill data on maps. Our staff field-tested it with good results, and SCS Field Services began using the application to visualize issues with wellfields that aren’t readily apparent when looking at spreadsheets.
A large SCS landfill client had seen our field staff using DataServices, asked if SCS would consider providing them with access to the application on a subscription basis. Our team adapted DataServices, added features, and continued improvements tailored for the client’s use.
As soon as secure data transfer became feasible, SCS moved to an Internet-based solution for our landfill gas practitioners. The platform called SCSeTools® holds the data collected by SCS DataServices®.
Applications and features roll out as we continually update and upgrade, incorporating ideas and improvements from our users and staff along the way. DataServices is addressing the landfill gas management needs of over 600 landfills across the US and Canada in 2021.
The keys to success follow our mission and values of maintaining close communications with our clients, field staff, engineers, and eTools support staff (all landfill gas practitioners), with the help of software engineers. Technology companies are not up at night thinking about landfill operations, but we are.
We introduce our SCS eTools landfill technology capabilities and a few of the creative and talented SCSers behind the technology in the next segment. Our speakers walk you through demonstrations of how over one-third of the landfill owners and operators in North America are increasing efficiencies using SCS eTools.
Visualizing Landfill Challenges – Shortcuts to Keeping Your Wellfield in Balance
DataServices shows the entire wellfield for any monitored parameters and zooms in on troublesome areas or wells. Results can be as simple or detailed as the landfill owners’ environmental and business needs dictate. The detailed examples here illustrate how graphs, maps, and charts help keep the wellfield in balance. We link each challenge to the description of a video demonstration.
In balance means extracting more gas for renewable energy, preventing odors and methane migration, keeps subsurface and surface conditions and workers safe. The information can help diagnose equipment conditions before they become costly, maintain regulatory compliance, and support cost estimates if the landfill is expanding or more infrastructure investment or equipment is needed.
Looking at vacuum distribution across a gas collection system – Select the system pressure map, which highlights vacuum distribution across the wellfield to show the wells with good (expected) vacuum, pressure drop over distance, and any wells unexpectantly losing vacuum. Zooming in and changing the vacuum ranges further enhances where to assign staff to troubleshoot any identified issues.
Using a methane distribution map shows whether the wells are tuned to where the landfill owner wants them. Wells may be identified below the targeted range, indicating slight over pulling; a technician can use this map to identify such issues and quickly check the identified wells. Wells identified above the desired methane tuning range indicate wells not collecting enough gas, which has consequences. These wells can be the source of odors, leachate seeps, possible lateral migration to an out of waste probe. Not sending enough fuel to a power plant or atmospheric releases can affect surface emissions monitoring.
Managing liquids – Changing waste streams and more rainfall in certain areas of the country complicates liquids management. DataServices visualizes the impacts of liquids on wells and helps landfill owners better manage a proper liquids removal program. The program will let them know how many pumps to budget for and, over time, where to relocate well dewatering pumps so that they are most efficient at removing liquids from landfills.
High-BTU Gas Plants –Filter maps help users locate wells contributing to gas dilution into renewable energy plants. It can help create punch lists for landfill staff to investigate, troubleshoot and tune. As wellfield technicians make corrections, they show on the map in real-time.
Temperature and subsurface oxidation events – Some call the condition subsurface fires, but this is a serious issue for landfills. Over-pulling wells, damaged infrastructure, and other conditions can cause oxidation events. Using a combination of temperature Parameter Maps to review wellhead temperature distribution and a Points Chart feature provides a deeper dive into the data. It provides more insight into which well or wells may be contributing to the high-temperature issues.
Locating a specific well – That’s not so easy when hundreds of wells surround you and at larger landfills. DataServices had built-in filter features to identify a single monitoring point on a wellfield map easily.
Customizing for compliance, best practices, and rules – DataServices allows monitoring points across a single site to have customized rules for each monitoring point. Rules can be for regulatory purposes, standard operating procedures, best management practices, and even site-specific preferences or any combination thereof. It is efficient to customize rule application to landfills and collection points – meaning wells, probes or ports, horizontal collectors. This customization capability helps organize and confirm regulatory compliance. It is especially salient with the 2021 EPA and state compliance changes for a single landfill or an organization with hundreds of landfills.
MobileForms – Inspection forms, blower flare station monitoring forms, load tracking from municipalities, incoming hazardous waste tracking, MRF bale counts are examples of paperless entry available. The data feeds directly from mobile phones to the supervisor and into the maintenance department, so staff can start cataloging and looking at what’s going on in real-time at several types of facilities. It’s available for regulators and inspections and helps reduce staff hours tabulating and centralizing the information. Any information historically captured on a form or log attached to a clipboard can now be captured and stored electronically. From there, it can be recovered and produced as a PDF export file or data from the forms used to trend data and help make informed operational decisions.
MobileTools – DataServices in a condensed format suitable for mobile devices. Field staff use MobileTools to save time formerly used to return to the office, transfer/transcribe the collected data and upload it to a supervisor for quality checks before storage. Technicians can now recall the last 20 readings for any given well and review trend graphs on their phones or tablets while standing adjacent to the well they have questions about and need to access the data. MobileTools also allows them to upload field data such as liquid level readings while the data is being collected. The information instantly populates into DataServices and is available for review by others on the project team.
The most valuable tools are in development now for release in 2022. ARC GIS integration developed under SCS RMC® will further enhance DataServices with even better visualization and location capabilities and provide enhanced features such as allowing landfill owners to see their well as-built information and view subsurface information about their wells.
Learn more at SCS Engineers, where we adopt our clients’ environmental challenges as our own.
Grace attends Virginia Tech University, studying Civil Engineering, and will be graduating in 2022. We are thrilled to tell you that Grace has accepted a full-time position with SCS after graduation. Lindsay Evans of SCS Human Resources interviewed Grace to get an inside look at her thoughts about SCS’s Internship Program.
What is your title at SCS Engineers? Would you please describe your responsibilities at SCS?
My title at SCS is Intern Engineer. My responsibilities include assisting the SCS Midlothian, VA office on a variety of projects, including landfill engineering, landfill gas engineering, and mining engineering projects. I also have done a good amount of Construction Quality Assurance (CQA) out in the field. I do a lot of engineering work within Civil 3D and technical reporting for EPA and VDEQ involving landfill gas monitoring and data review.
What was your favorite part about our internship program?
My favorite part of the program is definitely the intern presentation day. Although it is certainly nerve-racking, I love being able to hear what all the other interns across the U.S. were involved in at SCS Engineers.
How would you describe our company culture?
The company culture at SCS is one of my most favorite parts of getting to work here. As an intern, I have the opportunity to be a part of a team with responsibilities and access to a plethora of resources within my Midlothian office and throughout the company. It’s awesome that all SCS personnel are willing to help from far and wide; everyone is just an MS-Teams call away. I’ve had incredible mentors at SCS who fostered an amazing learning and working environment for me.
What advice would you give to future interns at SCS?
My biggest piece of advice is never to be afraid to ask questions! As I said before, there are so many experienced professionals at SCS, and as interns, we should definitely take advantage of learning from them! Asking questions enabled me to grow and learn more than I would have had I not asked.
On what cool project have you worked?
I’ve gotten to work on tons of fun projects so far, but a notable one is using Leapfrog Works and 3D modeling. I take data given to me by either field personnel or the client and transform a model depicting gas wells within the landfill. It provides a visualization of liquid levels and obstructions to each well. This is cool because I also create surfaces from the interpolated liquid elevations, which gives a better understanding of where the liquid is most present within the landfill, which could indicate higher temperatures.
Do you feel that your work at SCS has made a difference in our environment?
It is fulfilling to know that the projects I work on, such as emissions management and monitoring, reporting, and communicating, positively affect the environment.
What have you learned the most in your internship?
I’ve certainly learned a lot being an intern at SCS since the summer of 2020. Something that sticks with me is that it’s crucial to be reliable and rely on others to collaborate and work cohesively on project teams. The best projects are successful due to the effectiveness of the project team behind them!
Our clients and SCSers are excited to have Grace, another amazing YP, join SCS Engineers as an Associate Professional!
If you are interested in the internship program at SCS for the 2022 summer, please visit SCS’s Careers page in December 2021 to apply.
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