The Solid Waste Association of North America (SWANA) Applied Research Foundation released a report concluding that: a significant amount of additional food waste processing capacity will be required to achieve national, state, provincial, and local food waste diversion goals. The report also emphasizes the need for local decision-making in selecting and implementing those food waste diversion programs.
…a significant amount of additional food waste processing capacity will be required to achieve national, state, provincial, and local food waste diversion goals. The report also emphasizes the need for local decision-making in selecting and implementing those food waste diversion programs.
The report goes on to say that interest in recovering food waste from municipal solid waste is growing to meet goals established by the U.S. Environmental Protection Agency and U.S. Department of Agriculture, but many major metropolitan areas lack the infrastructure to manage the ability to meet the established goals. Two examples were cited:
Several states, including Massachusetts and Connecticut, condition their food waste diversion requirements on the ability of generators to access adequate capacity within a certain distance.
Speaking as SWANA’s Executive Director and CEO David Biderman stated:
We believe that Americans need to rethink how food is handled before it is considered waste, to divert it into programs to feed people, and to find other productive uses for food as food. Once it becomes waste, however, municipal decision-makers, working with their processing partners, need to determine how to best manage the material.
The SWANA report focuses on the effects of food recovery at the two lowest tiers of the hierarchy – composting and landfilling/incineration. The report concludes that food waste diverted from landfill operations has the potential to be processed at composting facilities. Then, going on to say that anaerobic digestion (AD) and co-digestion at wastewater treatment facilities are also likely destinations for diverted food waste.
Jeremy O’Brien, Director of the Applied Research Foundation, noted:
The food recovery hierarchy does not apply universally; an analysis of greenhouse gas impacts based on local data and conditions is needed to identify the best food scraps management options for a specific community.
The report encourages solid waste managers to perform a life cycle analysis of economic and environmental costs and benefits based on local needs, system capabilities, and data to identify the most effective ways to manage food waste at the local level.
SCS Engineers and SWANA are both long-time advocates for local decision-making in establishing programs to collect and manage municipal solid waste.
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Infrastructure Week (May 16–23) is a national week of events, media coverage, education, and advocacy efforts to bring the state of the nation’s infrastructure to the attention of all Americans. Forester Media, the publisher of MSW Management magazine, is an Infrastructure Week affiliate. John Trotti, MSW Managing Editor recently surveyed Jim Walsh, P.E., BCEE, President and CEO of SCS Engineers and long-time friend of the magazine on the topic. Jim is first out of the blocks to answer the four questions John asked of respondents from MSW and Forester’s other publications, Business Energy, Erosion Control, Grading & Excavation Contractor, Stormwater, and Water Efficiency.
MSW Management (MSW): Which infrastructure projects should be given priority? Roads and bridges? Dams and levees? Water supply? Electrical grid? Waste management?
James Walsh (JW): Typically public safety, cost, and benefit determine the priority for infrastructure projects, and different political jurisdictions have different priorities. Where highways and bridges are new but waste management facilities are old, the priority might be waste management facilities, and vice-versa. Some types of infrastructure are more amenable to private sector solutions, which can allow the government to focus on other types of infrastructure. The trend in waste management, for example, has been to rely on the private sector in the last decade
Each segment faces difficult challenges; the most significant is funding. Waste management does not necessarily have priority over other projects, but has progressed by regionally identifying the infrastructure necessary. Thus, each region avoids the pitfalls of competing for funding with other regions and other projects.
SCS Engineers focuses on waste management, but there are opportunities to interact with other segments in sustainable ways. For instance, we have energy clients who supply coal ash to specialty cement companies who use it to make “green” cements that last longer in applications such as road construction. We design and construct facilities that take the byproduct gases from the decomposition in landfills to generate electricity reducing their dependence on fossil fuels, or directly use the gas for energy to power wastewater plants simultaneously cleaning and conserving water. We find ways to safely redevelop contaminated property supported by existing infrastructure, thus reducing the need to build new infrastructure.
In short, we work toward helping clients find sustainable solutions to infrastructure projects.
MSW: Is there a solution to long-term infrastructure funding?
JW: With respect to the waste management infrastructure, waste systems require significant capital investment in land, equipment, facilities, and infrastructure. While many governments have decided to rely on private industry instead of financing new governmental facilities, others have become much more sophisticated in adopting private sector approaches to financing. Pro-Forma Economic Life-Cycle Models can assist governmental entities to identify the critical variables that can impact the success of an infrastructure project. Moreover, economic models evaluate how various components of a waste system and variable assumptions integrate together into a sensible approach. Pro Forma Economic Models allow for a careful analysis of the life-cycle costs and potential revenue sources and identify factors that will influence the waste system costs and demonstrate how to adequately and equitably fund the system. These Models provide different scenarios and eliminate options that are not financially feasible or do not fit a region’s short- and long-term needs or priorities. Sensitivity analysis can be conducted to understand better the impact these variables have on capital costs, operating expense, and the overall system economics. By assessing the economic and regional benefits first, we can focus on designing and building infrastructure solutions that are safer, longer lasting, and affordable. Other benefits include adjusting the Model if there is a major change in the commodity market, such as plastics’ recycling is experiencing now and when considering the use of new technologies.
Every industry segment and every region have a different blend of socio-political conditions, geography, and monetary resources—we assess and design to their particular needs. Adopting new waste management technologies, such as anaerobic digestion or waste diversion, as part of an overall waste management program can be integrated into the Model to study how, and if, they sensibly integrate within the existing program. New technologies are typically more expensive than mature technologies such as recycling facilities and landfills, but that condition alone is not why they are considered valuable to a region. The framework considers elements key to integrating anaerobic digestion for example into a long-term program. Capital investment, a significant centralized source of high-quality organic waste, power costs and economic utility incentives, limited land suitable for composting, lack of conventional waste-to-energy facilities, or a ban on organics disposal in landfills are some of the considerations.
Many states are developing organics diversion initiatives, discouraging or banning organics from landfills; they will want to develop separate capacity for diversion within their overall program to build a sustainable plan for the long-term. In some states there is plenty of environmentally sound landfill capacity, recycling facilities have adequate capacity, and the socio-political climate has different ideals. What works in Iowa might not be suitable for California.
MSW: What kind of harm is the current state of our infrastructure doing to the economy and the community?
JW: Every four years, the American Society of Civil Engineers releases a “Report Card for America’s Infrastructure” depicting our nation’s infrastructure condition and performance. In a traditional school report card format, individual infrastructure segments are assigned letter grades—solid waste has the highest grade of B- in the most recent report published in 2013. The waste management infrastructure in the United States is robust, diverse, and significantly supports our economy and communities by providing safe and cost-effective management of the materials that we discard on a daily basis.
MSW: What can various government entities—from local to Federal—do to attract private sector support and investment?
JW: In the United States, private solid waste facilities manage 75% of the municipal wastestream. The waste management industry has many examples of public/private partnerships and significant investment by the private sector. Just look at firms like Waste Management Inc., Republic Services Inc., Waste Industries, Waste Connections, WCA Waste Corporation, Covanta, and Wheelabrator, which own and operate numerous landfills, compost facilities, waste-to-energy facilities, transfer stations, processing facilities, alternative technologies, and hauling companies. These facilities require significant private investment. Allowing private industry to participate in the management of waste management infrastructure brings needed fiscal discipline and accountability to the overall waste system infrastructure.
The private sector is attracted to markets that are predictable and that provide an appropriate return on investment. Jurisdictions with a reputation for making sudden unpredicted changes in regulations that adversely affect the return on investment will find it difficult or impossible to attract private sector support.
The waste management sector and SCS Engineers have seen our share of magic technologies that are literally too-good-to-be-true, yet somehow attract governmental support both financial and otherwise. It is fine for government agencies to provide grant support for research related to promising new technologies, but adopting an unproven technology as the sole means of waste management is inviting a public health crisis. Private sector investment is not attracted to jurisdictions that have unrealistic expectations.
About James Walsh, PE, BCEE, President and CEO of SCS Engineers
Jim has worked at the forefront of sustainable waste management for more than 40 years. He has authored numerous publications, technical support documents, presentations for the USEPA, US DOE, the Gas Research Institute while serving the Solid Waste Association of North America (SWANA), National Waste and Recycling Association (NWRA), and the Environmental Research and Education Foundation (EREF), among others.
Long story short, an escapee from San Quentin and any uncontrolled methane air molecule may be more similar than we may presume. In fact, a common LDAR practice is to use an infrared imaging camera; similar to the camera often used in search of fugitive criminals.
On a serious note, fugitive emissions are something that both industry and regulators have been focused on for decades, and the past and present efforts made to limit them are no less than remarkable.
Specific to Onshore Oil and Gas Exploration & Production, the Federal Regulations applicable to fugitive emissions are fairly young. Finalized in 2012, NSPS OOOO is no longer a toddler and is in the middle of growing into NSPS OOOOa (Public Comment Deadline March 11, 2016). On a national scale, NSPS OOOOa will expand fugitive emission monitoring and control requirements (VOC’s and methane) to several facility types associated with the industry and is expected to be finalized before the close of 2016.
In California, fugitive emissions from Onshore Oil and Gas Exploration & Production have been regulated for a long time. In fact, the O&G industry in Santa Barbara County has dealt with fugitive emission requirements since 1979. Since then SCS Engineers has been assisting with fugitive emission monitoring for our valued clients. Today, SCS Engineers provides the Oil and Gas Exploration and Production industry with efficient and effective LDAR services.
So fear not, SCS Engineers is ready to supply the knowledge and skill set you need to stay compliant, maintain your operations, and respect your bottom line. Remember, unless the doors are closed, pumps are turned off, and equipment is flushed and plugged; fugitive emissions requirements and LDAR will likely still apply.
Applicability: Determining Federal vs. State oversight is the first step. Non-Major Source Oil and Gas Production facilities are either subject to NSPS OOOO (soon to be OOOOa) or a related State specific rule (i.e. Colorado Regulation 7). Once oversight is determined, then there may still be exemptions for your facility (i.e. facility constructed before August 23, 2011). And finally, once regulatory oversight is confirmed and you determine that LDAR is required for your facility, then the last step is to figure out which equipment is applicable (i.e. VOC content > 10% by weight). Basically, an applicability determination can be daunting.
Equipment: EPA’s Method 21 is historically and currently referenced in all LDAR regulations. Method 21 requires an instrument such as the Flame Ionization Detector (FID) or Photo Ionization Detector (PID). More recently the Optical Gas Imaging (OGI) Camera has been included in LDAR regulations and utilized in LDAR programs. Presently, there are several instrument technologies that exist and are in the works, but not yet mainstream in Oil and Gas sector. Ultimately, if you were to find yourself conducting LDAR monitoring at your oil and gas facility tomorrow per an established regulation, you would most likely need to use an FID or OGI.
Recordkeeping: Personally, I like the simplicity of using paper forms for field notes; however, the old-fashioned way comes with risk. The up-front and ongoing data involved with an LDAR program is too much for maintaining a paper to computer process, regardless of how organized you think you are. Therefore, a computer database platform is recommended and necessary for managing your LDAR recordkeeping. Beyond just recordkeeping, a database platform can organize schedules, alerts, generate reports, extract trends, and many other applications to help keep your LDAR program compliant. One such platform worth considering is SCSeTools™. This cloud-based software can provide the database capabilities used on the desktop, but almost more importantly, provides mobile data input capabilities with the SCS MobileTools™ application fit for Android and IOS systems. Keep the fugitives from escaping, and document containment for the authorities!
About Lucas Marsalek: Lucas has been an Environmental Consultant for over 8 years; he applies his expertise as a leader for oil and gas production environmental and regulatory compliance projects. Marsalek has a B.S. in Forestry and Natural Resource Management from California Polytechnic State University, San Luis Obispo, CA.
Whether you want to discuss LDAR or Dodger baseball, don’t hesitate to contact me, or SCS Engineers.
Resources:
Learn more on the SCS service pages and read SCS project case studies from across the nation to help fine tune your program.
Outside links to the EPA proposed rulemaking website:
Thirty-four senators and 171 representatives argue in a brief filed February 23, that the EPA overstepped its boundaries in creating the carbon-cutting Clean Power Plan. In short, the brief states that they feel that Congress never gave the EPA a clear statutory directive or authority to transform the nation’s electricity sector. The brief points out that the EPA seeks to make “decisions of vast economic and political significance” under a “long-extant statute,” and in doing so must point to a “clear statement from Congress.”
Yesterday’s brief comes just two weeks after the U.S. Supreme Court ruled the EPA cannot begin enforcing the rule until legal challenges filed by 25 states and four state agencies are resolved.
The D.C. Circuit Court of Appeals will hear oral arguments on the merits of the states’ case on June 2.
With the brief it is clear that the Clean Power Plan is not only facing legal challenges but also political ones. It may be left for the next Administration to pick up this pieces and decide the fate of the Plan.
SCS Engineers ranks 4th on the Los Angeles Business Journal’s list of the top 25 largest environmental services firms in the Los Angeles region. “We’re very proud of our environmental work in California and across the nation,“ stated Pat Sullivan, BCES, CPP, REPA, and a Senior Vice President of SCS Engineers. “It’s especially rewarding to know that we make a positive difference in our backyard and for the regional economy.”
See the Los Angeles Business Journal List
SCS Engineers – highly ranked for environmental consulting – San Diego Business Journal
The San Diego Business Journal listed SCS Engineers as one of the top Environmental Consultants in the region. The listing was researched and compiled by Courtney Shamrell of SDBJ. Environmental services covered by the list include; site assessments, environmental sciences, NEPA/CEQA activities, environmental remediation, work for federal and local governments, work for commercial enterprises, and other environmental engineering projects.
Thank you to our clients and to our environmental professionals who put SCS sustainable environmental solutions to work.
Denver, PA. – SCS Engineers is opening a new office in Denver, Pennsylvania. The professional engineering staff currently serving clients in Reading will be joined by additional environmental consulting staff moving to the larger office space on November 1, 2015. The new office is located at:
SCS Engineers
22 Denver Road, Suite E
Denver, PA 17517
Tel: +1-610-382-3050
Denise Wessels, P.E., and SCS Project Manager stated, “We are strengthening our commitment to the Commonwealth, and the new location enables us to broaden our environmental services in the region, including SCSeTools®.”
SCS provides quality environmental consulting and construction services to municipal and private sector clients, and has recently expanded SCSeTools®, a platform for organizing big data collected at landfills. The tools collect data, and then organize the data into analyses, graphs, and maps that allow landfill owners and operators to predict, assess, and plan the operation and maintenance of their facilities. This insight helps with decision-making for operational excellence and helps to improve the bottom line.
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