It goes without saying: landfill operators are forever working to stay on top of odors, especially when the community smells something and points to the landfill or when regulators come calling. This blog shares two odor stories: one around landfill gas and another around trash. Then it looks at what happened when an operator got a permit restriction over alleged hydrogen sulfide emissions; odor was not the problem here. It was a perceived health risk; learn how SCS proved a predictive model was off the mark.
Is Landfill Gas a Source of Community Odors? And Ensuring Compliance
Living up to landfill odor nuisance standards is tough. The underlying premise is that odors must limit peoples’ ability to enjoy life or property to create a public nuisance, but it’s a subjective call. How strong an odor is and sometimes even if it exists depends on perception, so the question becomes: when they aren’t sure what they are being measured against, how do operators comply and prove compliance?
SCS recently helped a client figure out how to accomplish this after receiving odor complaints from the community, ultimately leading to a state agency-issued violation.
“We needed to thoroughly investigate to identify and mitigate odors, then prove compliance to the state regulator. Making a strong, valid case without having a numeric standard to go by takes both creativity and a scientific approach,” says Pat Sullivan, SCS senior vice president.
Sullivan, a biologist and his team of meteorologists, air dispersion modelers, and engineers, had a good starting point. They knew landfill gas was the source of the problem. But they needed more data to get to the root of that problem, and the operator’s required surface monitoring did not tell enough of the story.
The team launched a series of studies relying on multiple investigative tools.
“When we may have to put in more gas collection components, as we did here, we want to be sure we install them exactly where they are needed. This entails going above and beyond the standard modeling with a more rigorous methodology to get a comprehensive landfill gas emissions footprint,” Sullivan says.
SCS began by bringing out a drone to reach more landfill areas than technicians on foot for better coverage. The drone can fly over slopes, areas too dangerous to walk due to constant movement of heavy equipment, and areas inaccessible because of snow and ice. As it flies, it shoots a laser, which identifies methane based on the light refraction by methane molecules—then incorporates the data into a map for a comprehensive, visual picture.
Knowing methane concentrations at specific locations is important, but determining where to be more vigilant in controlling landfill gas also requires knowing hydrogen sulfide (H2S) concentrations. Sometimes overall methane levels are within acceptable limits, but the hydrogen sulfide in it is elevated, which could be a problem, Sullivan explains.
Getting a good grasp on H2S’s potential impact is tricky, as levels can vary radically from one area of the landfill to another. Pat Sullivan, SCS senior vice president, has seen them range from 100 parts per million to as high as 100,000 at different locations.
SCS used a Jerome meter, a highly sensitive tool that precisely quantifies H2S down to low-level part per million levels. SCS took it across the landfill and then into the community in search of H2S hot spots.
At the same time that the team investigated surface emissions of H2S, they went deeper down, sampling each landfill gas extraction well for levels of this volatile sulfur compound to identify potentially problematic spots within the landfill gas system.
“For this, we used Dräger sampling tubes, a resourceful tool in that rather than sending 100 samples to the lab, we analyze them ourselves and get immediate results,” Sullivan says.
Technicians get accurate quantitative results within plus or minus about 20% and can view concentration readings out in the field. Results are recorded on field logs and entered into a database for future analysis.
SCS overlaid the methane data from the drone study with the H2S data on both surface emissions and wells to develop a roadmap to design a landfill gas system upgrade. It includes new wells and piping in focused areas and more blowers for increasing the vacuum to pull more gas.
“We saw immediate results,” Sullivan says.
“Total gas collected went up 15 to 20 percent. Complaints went down significantly, and our client has not received another violation since.”
Of course, as the landfill takes in more trash, it will generate more gas, so due diligence is ongoing.
“Problem-solving is a phased approach. You do what you determine to be most effective; evaluate; then do additional work to improve. We will continue to follow this site and fine-tune where needed to keep the system running efficiently and keep the community and regulators happy,” Sullivan says.
Taking Down Landfill Odors from Trash
New garbage on a landfill’s active face can be a source of offsite odors, but determining if the waste facility is responsible, and determining when, where, and how odors travel, takes forensic work. Landfill odor experts rely on multiple data sets and tools to understand what can be complex issues and ultimately devise the most effective odor mitigation program when necessary.
In a couple of recent scenarios in Southern California, SCS combined complaint data, meteorological data, and smoke studies to get a full picture that verified the decomposing waste was the odor source. Then staff helped nail down specific times the problem occurred and under what conditions; providing a concise window can save operators labor and other resources because they can execute proactive measures only when needed.
“We look at complaint data to learn the location, day, and time of the complaint, but these accounts are not reliable by themselves. So, we overlay this information with meteorological data to determine the wind conditions during those days and times. Weather-related data is important in vetting offsite odors because if the landfill is not upwind of the location when the complaints happen, there likely is another source,” says Pat Sullivan, SCS senior vice president.
Sullivan and his team begin their investigations in two possible ways – setting up meteorological stations at strategic areas on the landfill to capture wind-related data or capturing data from already situated stations. Then they produce wind roses from their findings, which graphically represent wind speed; how often the wind blows from certain directions; and how these two correlate. In these two scenarios, graphing wind data times during each day helped determine exactly when specific wind conditions are prevalent.
In one of the two cases, odors occurred in the summer and almost always in the morning. The data not only showed where the winds were coming from at those times, but also showed they were traveling at low to moderate speeds.
“We matched that information to complaints and confirmed that the wind conditions were indeed driving the odors,” Sullivan says, explaining the speeds were just enough to carry the odor molecules into the community but not high enough to disperse and dilute them.
“Now we have painted a picture of wind conditions that we can focus on to get more information. We are getting closer to designing a multi-tiered odor mitigation program,” he says.
The next step was a smoke study, which reveals how odors move offsite, identifying the exact pathways and movement trajectory. These details are important because to treat or disrupt odor molecules; operators need to intersect the odor plume before it leaves the site.
SCS odor experts release colored smoke at the time and location they believe odors are, based on the meteorological data. They film from a drone to get a bird’s eye view of the smoke plume as well as get a camera filming from a different angle, following the plume movement to identify its path out of the landfill. This method enables them to determine where to intersect the odors as they move through the air before leaving the site.
From this research came three recommended measures to take during unfavorable wind conditions:
One of the landfill operators now has the problem under control and has received no further violations.
The other site made many of the same changes and plans to open a second disposal area for smelly loads. This client has seen a significant reduction in complaints and violations, but it’s a work in progress. The next true test will come when Sullivan and his team reevaluate in the summer.
“We will see then if any improvements are needed and tweak the solution if needed.”
And as with our other clients, we are training operators on how to be proactive. We teach them how to identify and grade odors and how to follow set procedures. And we help them with strategy implementation,” he says.
Odor mitigation is an ongoing undertaking. The team continually assesses and quantifies emissions and potential impacts.
“We look for changes that will control odors or prevent them in the first place. And we provide clients with the know-how and support to stay ahead today and into the future. Landfills and waste volumes are growing and changing. It’s a dynamic scenario. And we continue to build on what we have proven and adjust to keep up to make more progress,” Sullivan says.
Showing That a Model Can Over Predict H2S Emissions
Hydrogen sulfide (H2S) can be problematic even at very low concentrations, so this volatile sulfur compound is on federal, state, and local regulators’ radar. Some jurisdictions require the evaluation of air toxic emissions to determine potential health impacts to nearby communities.
They are also calling for these evaluations during permitting or to decide when controls are needed. To make these impact determinations, regulators typically rely on standard H2S risk assessments leveraging air dispersion modeling that predicts concentrations at locations away from the source.
However, this methodology, which includes estimates of emissions and predicts offsite concentrations based on algorithms that mimic how air moves, is not always accurate. Inaccuracy proved to be the case at one SCS client’s site. The model overpredicted offsite measurements of H2S that the state and local agency classifies as toxic.
Ultimately, the client entered into an enforcement agreement with the state because the operator had a permit limit, based on results of the risk assessment that it could not meet.
“Respectfully, the agency came in maintaining that the levels were out of compliance; it came as a surprise and seemed questionable to our team given our experience. We felt that the air modeling and risk assessment results derived from this modeling were not accurate,” says Sullivan.
First, his team tried to adjust model inputs and variables that would yield what they believed would be more accurate data. Even though they could show improvements, the model adjustments could not obtain readings that showed compliance with the risk-based limits.
Next, they began going out monthly and measuring real concentrations at receptor locations. The team used a Jerome sensor, a highly sensitive handheld device that detects H2S down to single-digit parts per billion levels with good accuracy.
When they compared the predictions from the standard model to their readings on the same days of each month and same times of day, they confirmed the concentrations were well below the acceptable risk threshold.
“Because we did this over an extended period, we have continuous readings and a large data set from many locations that give a history and statistical validity,” Sullivan says. Every monitored value was substantially lower than the values predicted by the model.
“What that means is we could show that while there were onsite emissions, they were not escaping the landfill at levels that would exceed risk-based thresholds. That was useful in proving to the regulators that the landfill was actually in compliance with the standard, even when the model suggested it was not,” Sullivan says.
Now SCS is asking for revising its client’s permit and that the limitations are made more flexible based on real-time, longer-term findings. While the team is still waiting on the final permit decision, they’re confident they have proof that the site complies with the risk-based limit.
The outcome of this project has potential beyond possibly changing one permit for one operator, Sullivan surmises.
“We think the data developed from this study showing how the models can overestimate real-world conditions can ideally help other operators build a sound case in circumstances where they truly are in compliance.”
Related Resources
Staying Ahead of Odor Management at Solid Waste Facilities – This video recording is from a live session about the challenges of odors, including measuring them and the science behind them. Throughout the recording, the speakers’ field questions as they make recommendations for assessing and avoiding odors, regulatory issues, litigation, and responding to complaints.
The presentation and Q&A run for 1 hour 41 min. It’s well worth your time, with plenty of questions posed by solid waste facility operators, landfill managers, and composting operators answered.
SCS Engineers encourages you to share this video or any from our Learning Center. You can embed them at events and use them for in-house training. Look for our
SCS Engineers is expanding its environmental expertise with Nathan Williams, PE, as an Environmental Engineer in the firm’s Portland, Oregon office. Williams will support SCS’s growing client base in the region to meet and remain compliant with local, state, and federal regulations that impact their business or municipality, with particular emphasis on stormwater compliance and management.
Washington, Oregon, and Idaho clients have regulatory requirements that include Compliance Audits, Spill Prevention and Countermeasure Plans (SPCC), Stormwater Pollution Control Plans (SWPCP), Air Pollution Control Discharge Permits, Risk Management Plans, Form R reports and Resource Conservation and Recovery Act (RCRA) Part B. These plans and permits address regulatory requirements and help protect watersheds and wetlands that provide drinking water to downstream communities, habitat for fish and wildlife, and countless other public and economic benefits.
Williams brings expertise and credentials to provide comprehensive stormwater management services to support businesses in the region ranging from vineyards to landfills. His experience includes working on permitting and remediating contaminated sites for industrial, residential, and power generation reuse across Oregon and Washington.
As a Certified Erosion and Sediment Control Lead, Williams has extensive experience in erosion and sediment control projects, from design, permitting, implementation, and project closeout with final stabilization. Combining these skillsets helps businesses continue to deliver products and services on schedule as they encounter increasingly rigid compliance regulations.
As with all SCS Engineers employee-owners, Nathan Williams engages in industry associations and his community. Learn about Nathan and how his work on the SCS team helps municipalities, all citizens, and businesses thrive.
About SCS Engineers
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, watch a short video, visit our website, or follow us on your favorite social media.
$2 million in cooperative agreements is available for local governments to host Community Compost and Food Waste Reduction (CCFWR) pilot projects. The cooperative agreements support projects that develop and test strategies for planning and implementing municipal compost plans and food waste reduction plans. They are part of USDA’s broader efforts to support urban agriculture.
USDA’s Office of Urban Agriculture and Innovative Production will accept applications on Grants.gov until 11:59 p.m. Eastern Time on July 16, 2021. Projects should span two years, with a start date of September 25, 2021, and a completion date of September 25, 2023.
Local governments may submit projects that:
NRCS will assist in conservation-related activities.
Priority will be given to projects that include economic benefits; provide compost to farmers; integrate other food waste strategies, including food recovery; and collaborate with multiple partners.
The deadline for applications is July 16, 2021.
Project Example: The Department of Sanitation of New York and nonprofit Big Reuse establishes food scrap drop-off locations while New York City Parks Department is diverting wood chips and leaves from landfill disposal to create compost. GreenThumb, Brooklyn Grange, Hellgate Farms, Gowanus Canal Conservancy, and other urban farms distribute the compost for food production in the boroughs of Queens and Brooklyn, diverting approximately 600,000 pounds of food scraps and green waste from landfills and providing 350 cubic yards of compost to food producers.
Get Started with SCS’s ASP Composting Pilot Program
• Low-cost opportunity to test ASP composting feasibility
• Ability to test different feedstock mixes
• Assess the quality of the finished compost
• Assess odor control and process control
• Test footprint is 5000 sqft or less on your site
Webinar
A pre-recorded webinar will provide an overview of the cooperative agreements’ purpose, project types, eligibility, and basic requirements for submitting an application. The webinar will be posted at farmers.gov/urban.
More Information
Questions about this cooperative agreement opportunity can be sent to .
The Office was established through the 2018 Farm Bill and is designed to be a USDA-wide effort. Representatives from agencies throughout USDA play a critical role in successfully servicing urban customers. Other grant and engagement opportunities are available in addition to the CCFWR agreements. More information is available at farmers.gov/urban.
Additional resources that may be of interest to urban agriculture entities include NIFA grants, FSA loans, and AMS grants to improve domestic and international opportunities for U.S. growers and producers.
Partial Reprint from EPA Announcement
The U.S. Environmental Protection Agency (EPA) is announcing the selection of 151 communities to receive 154 grant awards totaling $66.5 million in Brownfields funding through its Multipurpose, Assessment, and Cleanup (MAC) Grants.
This funding will support underserved and economically disadvantaged communities across the country in assessing and cleaning up contaminated and abandoned industrial and commercial properties. Approximately 50 percent of selected recipients will be receiving EPA Brownfields Grant funding for the first time and more than 85 percent are located in or serving small communities.
The grant announcement includes:
The list of the fiscal year 2021 applicants selected for funding is available here: https://www.epa.gov/brownfields/applicants-selected-fy-2021-brownfields-multipurpose-assessment-and-cleanup-grants
Please spend some time with our experts as they help you negotiate funding, regulatory compliance, and helpful tools that will help your community prepare to remediate brownfields and other properties with a past into affordable housing, mixed communities bolstering economic development, stadiums, recreation facilities and parks, logistics centers…
SCS Engineers is expanding its environmental expertise hiring Richard Southorn, PE and PG, as Project Director in the firm’s St. Charles, Illinois office. Richard is a Professional Engineer in 13 states and a Professional Geologist in Illinois and Delaware. He will support SCS clients with their coal combustion residual (CCR) and municipal solid waste projects, including facilities for composting and the safe management of hazardous wastes.
As a Project Director, he runs teams providing comprehensive services ranging from construction plan development to full-scale design services. His client responsibilities include the coordination and supervision of the project teams made up of professional engineers, geologists, technicians, planners, and support staff.
Richard has expertise in developing site layouts and analyzing designs for multiple landfill facilities. These designs fit within the comprehensive environmental services landfill operators need to manage these complex, integrated systems. Richard’s design approach for landfill infrastructure integrates the elements that all play a role in environmental due diligence, including the landfill base and final cover liner systems, leachate extraction and cleanout systems, landfill gas control systems, and stormwater management controls.
As a licensed Professional Geologist, Southorn also oversees geotechnical stability evaluations, stormwater modeling, and the design and evaluation of landfill gas systems that minimize greenhouse gases. He has overseen many hydrogeological investigations that characterize subsurface stratigraphy, hydrology and hydrogeology, protecting groundwater for safer and more efficient facilities.
As with all SCS Engineers employee-owners, Richard engages in industry associations and his community. Learn about Richard Southorn and how SCSs’ work protects all citizens.
About SCS Engineers
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, watch a documentary, or follow us on your favorite social media. You can reach us at .
Fast-growing small to medium-sized businesses that use common chemicals and generate waste may be at risk for fines because they’ve grown into unfamiliar regulatory territory. Recently while helping a small business experiencing rapid growth, it occurred to me that many small and mid-size businesses generate waste that meets the EPA’s definition of “hazardous waste,” and the EPA is uncompromising when it comes to managing and disposing of hazardous waste.
While there are somewhat complicated requirements for storing hazardous waste at businesses and facilities, understanding them to maintain reasonable insurance rates and a safe work environment is worth every minute of your time. You’ll not only avoid fines, but your workers can easily avoid creating unsafe work conditions. My blog intends to help simplify the regulations to begin looking at your business as it is growing.
First, let’s define the terminology.
There are exceptions to these terms, but these are the basics to help the average business manager understand a complex and complicated set of regulations.
The basics of understanding hazardous waste storage and management
There are many requirements for storing and labeling waste and issues related to safety, like not storing acids in metal containers or storing two incompatible wastes close together that could react and cause a fire or explosion.
For our purposes, remember that you must have a single dedicated hazardous waste storage area, and the storage area is subject to many design, construction and operating requirements.
Each type of Generator has a storage time limit and must dispose of hazardous waste from a facility or business before the deadline. Large Quantity Generators have 90 days from placing the first waste in the storage container (accumulation start date), and Small Quantity Generators have 180 days. It is mandatory to write the accumulation start date on the container label when the first waste goes inside.
Realistic Safety Protocols
For small to medium-sized businesses Generators, it isn’t practical to have employees carrying small containers of waste to a storage area each day or at the end of each shift. It’s inefficient and could lead to the accidental mixing of incompatible wastes. It is better to have one or two trained staff responsible for placing wastes in storage containers and keeping the labels current. To help, the EPA allows for “Satellite Accumulation” of hazardous waste at the point of generation (the shop, workstation, etc.). A facility can have multiple Satellite Accumulation areas, but each area must meet these requirements:
A Growing Small Business Case Study
As mentioned earlier, let’s discuss the real-world example that got this blog started. A company started a metal container painting operation and was not familiar with hazardous waste regulations. Like many, starting as a very small operation, they were lucky, and the business grew larger over a short period.
Along with growing business comes a growing facility to accommodate it, but managing all the change creates an opportunity for some things to slip between the cracks. Employees didn’t know they could not toss partially filled paint and solvent containers in the facility’s dumpster.
During an EPA inspection, the company was subject to an enforcement action for failing to characterize their waste and improper disposal of hazardous waste, among other violations. The inspection results spurred business fines, and although the EPA has the option of pursuing criminal charges, they did not in this case.
Simple, Practical Steps to Compliance
Upon review of the records, tour of the facility, and understanding the workflow, the company took the recommended actions creating satellite accumulation areas and a hazardous waste storage area. Starting with establishing the storage area first, we also obtained an EPA ID number for the facility.
The next important step is training employees on the hazardous waste requirements pertaining to their jobs. Because some of the paint is water-based (typically non-hazardous), the facility now trains its employees to separate water and solvent-based paints and waste products, saving on disposal costs.
The company knows it is growing at a rate that will generate more than 1,000 kg/month of paint and solvent waste; therefore, it makes sense to register as a LQG. One employee is now in charge of hazardous waste management.
There are five bulk paint stations and a touch-up operation for small parts, so six satellite accumulation areas are now functioning. Each area has a 30-gallon waste container to prevent accidental accumulation of more than 55 gallons. Busy painters tend to put waste in buckets if the drum fills before their shift ends. At the end of each shift, the hazardous waste manager checks each satellite accumulation area and transports full or nearly full containers to the hazardous waste storage area.
For less than the cost of the final negotiated fine and legal fees, the facility has a compliant program and is receiving very favorable regulatory inspections.
If you want to dive into the details of this topic, this link to an EPA Frequently Asked Questions webpage may be of interest: https://www.epa.gov/hwgenerators/frequent-questions-about-hazardous-waste-generation.
About the Author: Jim Oliveros, P.G is a Project Director in SCS Engineers Environmental Services practice. He has over 35 years of experience in the environmental consulting field, including hazardous waste permitting, compliance, and corrective action. Jim is experienced in conducting assessment and remediation of contaminated properties, completing multimedia compliance audits, assisting with waste stream identification, characterization and management; and, federal and state regulatory policy. He embodies SCS’s culture of delivering great results to his clients, on time and within budget.
Local governments feed tens of thousands to millions of dollars into their landfills long after closure to continue protecting the environment and people, compelling some of them to find creative ways to offset post-closure maintenance costs and to potentially profit. In some cases, these localities convert closed landfills to active, useful community assets.
Two Maryland counties are among recent SCS Engineers’ clients who are converting their idle properties into revenue-generators that serve their communities—they are installing solar farms, a growing trend on closed landfills. This is consistent with the U.S. EPA’s Re-Powering America’s Land Initiative that encourages renewable energy development on landfills.
Siting solar energy installations
These sites are fairly flat, open spaces conducive to solar installation, and most are near power lines and in regions where real estate is limited and high-priced. While properties like these Maryland landfills provide ideal locations and are inexpensive, the projects command a robust multidisciplinary redevelopment approach. It takes proficiency in environmental and civil engineering designs that protect natural resources while maintaining landfill integrity. Look for consultants with both landfill and brownfields experience who know permitting processes, are up on local regulators’ hot spots, and have established relationships with energy service companies.
One of these projects on a closed county landfill will be a 6-megawatt system, sprawling over 170 acres, the largest solar project on county property. It will provide inexpensive, green electricity to low- and mid-income families, enough to power 930 homes, as well as power county buildings.
SCS Engineers was selected by Ameresco, the solar developer for both projects, to develop the required state and local permits. As the solar developer, Ameresco is performing turnkey services for the projects, including solar design, interconnection with the utility for sale of the electrical power, and operation of the solar systems consistent with a long-term agreement with both of these counties.
“This project will provide financial relief to people of the county and also help fulfill our client’s goal to advance green infrastructure and operations in county buildings,” says Mike Kalish, SCS Engineers Project Manager.
A full understanding of local regulations and proven engineering designs are key to success.
Pulling together the detailed engineering components to secure the state permit and local approvals are involved processes. Knowing the regulatory programs and potential impacts of the design and construction are key to quick and efficient navigation of the approval processes. “The faster you can get through permitting, the better for communities who want access to power. The county officials have made this decision while Ameresco is investing significant capital, and we want to assist in project implementation to enable a return on that investment as soon as possible,” Kalish says.
He and his team key in on what regulators look for and their anticipated trigger points and work to stay a step ahead.
“Because of our familiarity from prior work at these sites, we were able to avoid costly site investigations, thereby saving time in the permitting processes,” Kalish says.
SCS supports clients not just in developing designs that meet regulators’ requirements but verifying, documenting, and demonstrating compliance with all aspects and considering the long-term needs. For instance, meeting the fire marshal’s codes showing the proposed roadway design meets stipulations around access into the site and around solar panel arrays.
“We also take great care to maintain the cap’s integrity and ultimately its closure certification,” Kalish says. “But we have a holistic plan that accounts for more than the cap to be sure that the landfill is in its existing condition once we complete the project. For example, the solar panels mount on a series of ballast blocks that sit on the ground surface; there is no digging involved.”
“We are attentive to mitigating impacts to natural resources and ecosystems, just as we are diligent in protecting the landfill.”
“There’s also adjacent forest we need to go through to connect to the electric grid. So, in our evaluations, we take into account design considerations and impacts to forest conservation regulations as well,” Kalish says. “Maximizing development while protecting sensitive resources, as well as valuable capital assets, is a priority.”
“That’s a quick turnaround considering the diligence and attention to detail that large solar projects require, but it’s important to our client, so it’s our priority too. This is when knowing local regulations well is most valuable. As important is that we have a long-standing relationship with the client where we know the site’s history – all key to being able to move quickly and safely.”
The SCS Engineers and Ameresco Team
SCS is working with Ameresco, one of the largest renewable energy project developers in North America. SCS and Ameresco have very complementary skills. Whereas SCS has decades of experience in landfill engineering and permitting, including varied post-closure uses for landfills such as solar, Ameresco has extensive experience with renewable energy to provide comprehensive turnkey services from electrical design to managing the interconnect to the grid to negotiating the purchase agreements for the sale of power to utilities. The teaming relationship is vital to executing successful projects from feasibility study to design, all the way to completion.
“Ameresco is a very big player in energy, and we are large in the landfill engineering space. Both companies have offices nationwide. We work on over one-third of the landfills in the United States. Together, we have an expansive reach and breadth of experience in every essential competency to offer successful solar projects on closed landfills,” Kalish says.
Solar Energy on Brownfields and Closed Landfills
The Virginia Composting Council is the state affiliate of the US Composting Council; its mission is to support the efforts and initiatives of the USCC and bring the practice of composting to more Virginians. The Composting Council is growing because of increased efforts by communities to divert food waste from disposal. Demand is growing with increased awareness of composting’s beneficial uses.
The Virginia Council, led by President Ryan Duckett of SCS Engineers, cites the obvious benefits of less waste going to landfills and lower greenhouse gas emissions in the environment. He also points out the jobs and business development potential and using compost for stormwater management, erosion control, and other green infrastructure as benefits. Expanded programs also offer the opportunity to collect edible foods for non-profits feeding many in need while diverting non-edible organics to composting.
The Council brings together manufacturers, municipal managers, organics collectors, researchers, and other compost allies in the waste industry. The group works to educate state regulators, local officials, and the public about composting’s value in a circular system. Members also help develop positions on regulations and legislation that affect composting and the market.
USCC has 13 state chapters that do local work to advance the composting industry alongside the national advocacy and programs. Without their on-the-ground education, attention to and work in regulations and legislation, and building networks of people in the industry, USCC could not be effective.
Vapor intrusion is a regulatory hot button gaining traction on states’ radar nationwide. This is driven by a growing understanding of how vapors travel through the soil into structures, posing health risks to occupants, coupled with research showing volatile vapors can be problematic even at very low concentrations.
As in California, conservative assumptions by regulatory agencies call for careful due diligence during the assessment process. These salient concerns recently brought a real estate developer in Monrovia to seek a professional engineer.
The client plans to convert a commercial property to residential use. But before moving forward, it needs to assess potential environmental issues associated with the property. That’s where SCS comes in, drawing on its concrete knowledge base in geology and chemistry—and leveraging its grasp of regulatory requirements.
The work in Monrovia entails a detailed soil vapor assessment, looking for volatile organic compounds (VOCs); the discovery at this site came as little surprise to Julio Nuno, Senior Vice President, and Project Director, as these constituents are often found during evaluations of this kind.
Assessing for VOCs
In this case, the soil contained eight VOCs, some at non-compliant levels. The good news is, after an extensive, multi-step vetting process, Nuno and his team came up with a relatively inexpensive solution to tackle a potentially daunting problem.
“As part of the soil vapor assessment, we compare concentrations we find on-site to screening levels established by the Department of Toxic Substances Control. We often see levels in exceedance of regulatory thresholds, particularly in industrial areas with releases that can travel from groundwater to soil into the building through the slab,” Nuno says.
Most prominent at the Monrovia site were two chlorinated compounds that have been used as solvents in industrial applications: tetrachloroethylene, also called PCE, and trichloroethene, or TCE. PCE is commonly present in industrial settings and communities as drycleaners widely and routinely used the chemical for decades.
Nevertheless, the work begins even before confirming VOC levels and other specifics around these compounds. The first step is a Phase I Environmental Assessment looking to see if past use of the property or surrounding property may have left a significant environmental impact. The SCS team discovered the adjacent property had a release of VOCs they identified as a ‘recognized environmental condition,’ meaning it needs further evaluation using a Phase II to determine if vapors could migrate onto the client’s property.
During the Phase II Environmental Assessment –the collection of soil and soil vapor samples –the SCS team gets even more specific, determining what’s present, specific locations, what degree of contamination, and what these findings mean for redeveloping the property and its final use.
“We confirm subsurface concentrations and if they exceed state screening levels, and if the site represents a potential risk for future residential use. The information informs our possible solutions to mitigate any migration of certain VOCs into the building and the indoor air,” Nuno explains.
Redevelopment Goals – safety and cost containment
Safety comes first, but containing project costs is a priority, which comes down to knowing design options, how to piece components together with both function and economics in mind. At this site, achieving safety and controlling costs centered largely around looking at the mandatory infrastructure– a ventilation system for a planned underground parking garage to prevent accumulation of carbon monoxide and other vehicle exhaust emissions.
“We knew the underground parking would require a ventilation system. It makes sense to look at the parameters associated with that design to verify if it serves dual purposes to ventilate the garage and mitigate the potential for VOCs to enter the building,” Nuno says.
By studying air exchanges that would occur, the number of times replacing air-containing pollutants with cleaner air per hour, Nuno gets his answer. “We determined that a second, separate system would not be necessary for sufficient ventilation; the assessment enabled us to confirm vapors would not travel into the residential portion of the building.”
The client can save $50,000 to $75,000 in capital expenses upfront while achieving their safety goals and avoids ongoing operations and maintenance costs for added infrastructure.
An added layer of protection
Identifying the issues for site developers and their tenants, then plotting the best course of action to ensure safety and regulatory compliance takes experience and knowledge. SCS devises a soil monitoring plan, alerting developers of indications of potential contamination to the soil, of odor, or anything unusual that could suggest an environmentally adverse condition. The plan advises on how to respond should there be an unexpected condition adding a further protection layer.
“It’s essential that an engineer understand the applicable federal, state, and local standards for completing assessments, as well as understand regulatory stipulations. You must also know the variations in those stipulations to effectively design a sustainable plan,” Nuno says. “In Monrovia, we comply with the Department of Toxic Substances Control requirements, the requirements of the Los Angeles Regional Quality Control Board, and others. Each has specific stipulations for evaluating each contaminant. So, we stay on top of which rules apply to which location,” he says.
Nuno has submitted a draft report for review by his client and its legal counsel; he’ll meet with them to discuss findings and explain their meaning. SCS includes an executive summary, explaining in plain language what is salient; often, a backup report includes thousands of pages. “It’s a lot of complex information, so we work on the language,” Nuno says.
“It’s important to paint an accurate picture and use terms that all parties, whether the client, investors, or other stakeholders understand. These redevelopments are major projects with many due diligence considerations. We want to provide accurate findings and recommendations that the client and their advisors can digest to help them with their decision making.”
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SCS Engineers provides comprehensive environmental due diligence services nationwide and announces two new SCS National Experts to lead the expanding practice. Vice President Michael Miller and Project Manager Justin Rauzon take the helm to meet the expanding demand for these environmental services. Mr. Miller is in SCS’s Omaha, Nebraska location and Mr. Rauzon in the Long Beach, California headquarters office. Both professionals work nationwide and continue to support their regional clients in their new positions.
Miller focuses on comprehensive environmental management and consulting for private and federal clients. Project solutions typically involve solid waste, hazardous waste, environmental assessment, compliance audit, feasibility studies, environmental permitting, and training. His environmental due diligence experience includes work at fuel storage and vehicle maintenance facilities, petroleum retail sites, agricultural, chemical processing, and pharmaceutical manufacturing plants, active and closed landfill sites, abandoned chemical disposal sites, and numerous dry cleaner sites.
Mr. Rauzon has a diverse background in biological and environmental sciences and regularly performs environmental assessments and compliance audits at North American sites. Rauzon’s technical and management experience is with soil, soil vapor, and groundwater investigations on industrial, commercial, landfill, greenfield, and residential properties. He has extensive experience with environmental laws and regulations in the United States and Mexico.
Both work through all project phases, from developing cost estimates to implementing due diligence tasks ranging from site assessments to full remediation. SCS Engineers’ Environmental Due Diligence and All Appropriate Inquiries practice is comprehensive. The practice’s services cover Environmental Insurance Claims and Underwriting Support, Financing and Company Acquisition Support, Property Inspections and Abatement, Property Transactions, and Solid Waste Management Financing.
SCS’s Brownfields and Voluntary remediation engineers rely on the due diligence practice and developers, contractors, municipal officials and city managers, and advisors such as banks, insurance firms, and attorneys to private and public entities.
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