On August 17, 2023, the United States Environmental Protection Agency (EPA) released the first of twelve datasets (representing approximately 7% of the total data that it plans to collect) on 29 polyfluoroalkyl substances (PFAS) and lithium (an alkali metal) in our nation’s drinking water. This sampling will continue through 2026, and is the latest action delivering on the EPA PFAS Strategic Roadmap, which dictates that PFAS (an emerging contaminant pending regulations under CERCLA) requires a multi-agency approach and specific actionable steps to assess risks to human and environmental health better, hold polluters accountable, and identify the extent of the problem.
Monitoring PFAS and lithium is currently under the fifth Unregulated Contaminant Monitoring Rule (UCMR 5). The Safe Drinking Water Act (SDWA) requires that the EPA issue a list of unregulated but potentially harmful contaminants every five years and devise a protocol for monitoring those contaminants in public water systems (PWSs).
The current UCMR 5 regulatory framework allows for collecting PFAS and lithium data throughout the United States. It aims to create science-based decision-making regarding how to address these chemicals best. Results, which will get quarterly updates, can be reviewed by the public on the EPA’s National Contaminant Occurrence Database.
While there is not currently a final drinking water standard in place for PFAS, EPA has already issued health advisories for four PFAS compounds, and two of them – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – have also been proposed for entry as hazardous substances under CERCLA, as of March 2023. The timeline for the final rule on PFAS CERCLA designation is now February 2024. Landfills and other passive receivers are seeking relief from CERCLA contribution litigation prior to designating PFAS as hazardous substances, as they have no control over the use and disposal of hundreds of thousands of products containing PFOA and PFOS.
This first set of data does appear to raise some red flags, though it is not uniformly indicative of widespread contamination. In Missouri, for example, 1,923 distinct water samples were obtained from 22 different PWSs (from a mix of wells and treatment plants) in communities throughout the state. Of these samples, 23 are scattered between 11 facilities containing lithium at concentrations in excess of the laboratory Method Reporting Limit (MRL) of 9 micrograms per liter (µg/L), some by many orders of magnitude. Only two PFAS compounds (PFOS and PFHxS) are above their MRLs (0.004 µg/L and 0.003 µg/L, respectively), both from the North Rodeo Well of the Camdenton PWS.
This data will ultimately be immensely useful for public sector officials trying to make policy decisions regarding PFAS and lithium management, fine-tuning community engagement/education efforts, and for private sector industries seeking to get a handle on potential liabilities. SCS Engineers and other qualified environmental firms are poised to be essential partners to national leaders in identifying and remedying emerging contaminants such as PFAS. Many technologies proven to work on a large scale are available, with more promising technologies on the horizon.
Find additional regulatory information using the links below:
Impacts on Sectors and Treatments:
About the Author: Rachel McShane, LEP, has over 15 years of experience in environmental due diligence projects (Phase I, II and III Environmental Site Assessments) as well as Brownfields redevelopment, risk-based corrective action, and remediation projects. She is familiar with National Environmental Policy Act (NEPA) environmental assessments, vapor investigations and mitigation, radon, asbestos, lead-based paint surveys, and leachate monitoring/solid waste management. Reach Ms. McShane at or via LinkedIn.
In her paper, Utilizing Multiphase Flow Modeling to Estimate CO2 Solution Storage Efficiency and Sequestration Project Size, author Kacey Garber discusses how developing an understanding of CO2 storage efficiency and CO2 capacity estimates for a Carbon Capture and Storage (CCS) project will help you properly scope your project location and therefore maximize the benefits CCS has to offer.
The storage component of a CCS project requires a Class VI Underground Injection Control permit to inject supercritical CO2. These permits require multiphase flow modeling to delineate both the extent of the injected supercritical CO2 and areas that exceed a critical pressure threshold as a result of injection. SCS has found this modeling to also be valuable during project scoping to provide a sense of the total CO2 storage capacity for a given project.
Kacey walks through a case study that utilized a multiphase flow model to investigate what operational parameters would lead to the most efficient use of pore space for a CCS project in development. This included examining the effects of different injection rates, durations, and locations and investigating multi-injection well scenarios. This case study ultimately shows that a multiphase flow model will help you meet the requirements for your Class VI injection well permit application; it will also help you right-size your CCS project during the planning phase. Incorporating project-specific considerations into the model will help you identify operational conditions ideal for maximizing CO2 storage efficiency.
Additional Resources:
Many companies are exploring carbon capture and sequestration (CCS) to help reach greenhouse gas emission reduction goals. Protecting aquifers is a primary concern for the public to safeguard underground drinking water sources. Starting with near-surface background environmental monitoring is the first step to addressing public concerns and maintaining safety.
A comprehensive monitoring plan helps preserve the safest conditions and can save time and expense during injection and post-closure care. This SCS Engineers webinar explains the concepts, how it protects aquifers, and what to look for in a background monitoring plan. Establishing baseline conditions before injection is the first step. Starting immediately after submitting the Class VI permit application, during the regulatory technical review period provides the time to take these important baseline measurements.
Dr. Charles Hostetler, with nearly four decades of experience as an engineer and hydrogeologist protecting aquifers, explains why near-surface monitoring is important to meet demands for addressing environmental concerns during the design and operation of a CCS project. His expertise helps protect aquifers and save time during the design, build, and operation of CCS wells through closure.
Siamak Modarresi joins SCS Engineers in our Bellevue, Washington, office location as the newest member of our Environmental Services practice. Modarresi supports SCS’s Landfill Leachate and Industrial Wastewater Treatment teams throughout North America.
Modarresi earned his BS and MS in Chemical Engineering and obtained his Ph.D. in Environmental Engineering from the University of Washington. He has his PE in Chemical Engineering in California.
He most recently worked for a global sustainability firm providing design and project management for membrane bioreactor (MBR) treatment systems. This experience and knowledge translate as direct value to SCS’s clients, who face strict regulatory wastewater laws, emerging contaminants, and increasing costs for operational pretreatment systems.
Water fulfills critical functions in all industries, but much of the water results in industrial wastewater. Every effort is made to reduce water usage and treat wastewater to make it reusable or safe to discharge. Recycling wastewater is a feasible, cost-effective option. Newer, industrial water purification technologies that scale and are field-proven make it economically and environmentally feasible. Following treatment, wastewater can become an asset instead of a potential liability.
“SCS handles these complex projects, including developing pretreatment systems for FOG, ammonia, heavy metals, high-strength wastewaters and leachates, and mixed waste streams,” said Greg Helland, vice president, and the northwest region business director. “Membrane bioreactors treat high organic strength wastewaters, and anaerobic MBRs can provide a revenue source as renewable energy; that’s where Siamak’s industry expertise supplements our teams’ value.”
Additional Information and Opportunities
Class VI Underground Injection Control Well Permitting is Part III of our video series on Carbon Capture and Storage. Cutting through red tape and regulatory barriers is key to keeping the permitting process on track for your Class VI UIC well. There are steps you can take to prevent delays and meet key regulatory requirements.
Watch the SCS’s Carbon Capture and Storage webinar to learn more about each phase of the permitting process and how to keep each running smoothly. Carbon capture and storage is an EPA-approved technology companies are exploring to help them reduce their greenhouse gas emissions, and understanding the permitting process is key as you plan your project. In this chapter you’ll get answers to these questions:
Your business does not have to be in Illinois to learn from these educational webinars. If you’re ready to explore the benefits of carbon capture and storage but concerned you’ll get delayed by the ins and outs of the Class VI UIC well permitting process, watch Patty Herman’s video to learn more, or contact your local SCS office for a consultation.
Patty Herman graduated from Southern Illinois University Edwardsville with a Master of Science in Biological Sciences. Working in diverse and unique habitats enhances her awareness of the ecosystem’s fragility and the need to protect it, especially for agencies during the permitting process. During graduate school, she was selected by the Illinois Department of Natural Resources for the Natural Heritage Residency program. The residency provided exposure to resource management in both public and private sectors, interacting with many federal, state, and local agencies, as well as NGOs and landowners. She writes and executes management plans and permits using her intensive experience in land management techniques. She has the unique ability to find common ground with stakeholders, agencies, and the public in safe land management for industrial and manufacturing.
Additional Resources:
COMM22, a master-planned, mixed-use development project on a former brownfield, receives the 2023 Phoenix Award as an outstanding development on a revitalized property. The national premier awards program for brownfield redevelopment reflects the progression of brownfield redevelopment over decades and recognizes extraordinary practitioners and projects such as COMM22.
SCS Engineers will be at EPA’s Brownfields 2023 Conference to accept the award on behalf of the COMM22 team. The COMM22 development is the result of a collaboration between BRIDGE Housing and the Metropolitan Area Advisory Committee on Anti-Poverty (MAAC) in partnership with San Diego’s Unified School District as a public-private partnership.
“The COMM22 team is honored by the Phoenix Award. Many partners are part of transforming this once-underutilized school district site into transit-oriented affordable housing connecting people to jobs and services. I am pleased to thank them all. Our mission at BRIDGE Housing is to strengthen communities and improve the lives of our residents, beginning – but not ending with affordable housing. COMM22 is an excellent example of the collaboration and creativity required to address a housing crisis of the magnitude we are facing. On behalf of BRIDGE and the entire COMM22 team, it is my pleasure to extend our appreciation to the organizers of the Brownfields conference and the Phoenix Award.” said Jeff Williams, director of development for BRIDGE Housing.
The COMM22 team took an abandoned and contaminated property in a mixed residential and commercial neighborhood to create a thriving hub of residences reinvigorating the area and providing stable homes for hundreds of low-income individuals, elders, and families.
Brownfield revitalizations have grown substantially with public, private, and nonprofit practitioners nationwide who depend on brownfields as a strategic function of planning, economic development, environmental quality, and community development. The COMM22 project, for example, provides over 200 affordable housing units, 13,000 square feet of commercial space, a 4,200 square foot child care facility, and 11 affordable for-sale townhomes in San Diego, CA.
The affordable housing units are separated into 70 senior housing units and 130 family housing units. Paseo at COMM22 Family Housing in Logan Heights has 130 apartment units, 13 serving youth eligible for supportive services on a referral basis. The remaining units are available to low-income families and individuals.
Victoria at COMM22 offers 70 affordable housing units for seniors 62 and older. Victoria has 40 studio, one- and two-bedroom apartments with affordable below-market-rate rents and 30-one-bedroom apartments with HUD subsidized rents.
SCS Engineers’ role in supporting the environmental conditions at the site spans over ten years, including environmental assessments, waste characterization, mass grading, and design and implementation of a successful remediation program; thus delivering housing that supports both the social and business goals of the development team and the community.
“The technical issues were challenging, but it’s amazing to see the transformation of vacant lots into vibrant housing that anchor the neighborhood,” says Dan Johnson, SCS Engineers vice president. “We are proud to be able to provide the highest level of environmental and regulatory support for the community.”
The completed COMM22 housing development is a transformational project that has brought tangible benefits to its residents and the entire community. What was once an abandoned, contaminated property is now a thriving cornerstone for the whole neighborhood and a model for transit-oriented infill development and affordable housing with a noticeable increase in the quality of life and a palpable pride of ownership.
Additional Resources
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We hope you were able to join SCS Engineers for our follow-up presentation to Black Goo I. In this live session, we welcomed Dr. Craig Benson, who is studying black goo for the Environmental Research & Education Foundation. Joining Dr. Benson were landfill and leachate engineers and an expert who brings in-field expertise for a holistic presentation.
Landfills are experiencing a phenomenon called “black goo,” solids that make their way into leachate and gas collection systems, clogging equipment and impairing the management and extraction of leachate and gas. The viscosity differs between facilities, hardening like concrete or staying pliable. It attaches to pumps and check valves and settles in sumps, causing problems for leachate collection system cleanouts and landfill operations.
With funding from the Environmental Research & Education Foundation, Craig Benson provided information from his team’s studies, and our panelists discussed how goos move through waste into the infrastructure and how to remove it or keep your systems functioning. Ultimately, this and a growing base of information will help us to prevent the goo problem from happening in the first place.
Who Should Watch and What You’ll Learn?
Goo II is for those in wastewater operations, landfill owners, operators, technicians, field personnel, engineers, and regulators interested in learning more about goos. We covered these topics:
SCS forums are strictly educational.
Carbon capture and storage (CCS) enables industry and manufacturing to reduce greenhouse gas footprints by up to 2 million metric tons annually, for decades. It’s a great time to learn how this technology works, how it can help you, and what the overall lifecycle of a CCS project looks like. In this chapter, Kacey Garber and Candy Elliot step through best practices based on project experience, regulations (in this example Illinois), and the compilation and submittal of permit applications. You’ll learn about:
Your business does not have to be in Illinois to learn from these educational, non-commercial webinars. Transform how industry leaders like you manage greenhouse gas as a byproduct of modern life.
Helpful Basic Tips:
Early planning and mindful project scoping are critical for a CCS project to understand and communicate the project’s needs, objectives, goals, and conceptualized design. Use site characterization data and have a good handle on the operational parameters to develop a good first model and initial area of review delineation. The monitoring system design should then be tailored based on those data. Use the baseline and operational monitoring data to calibrate the model and refine your area of review delineation.
Early financial planning is also important and should include long-term operations and monitoring. Spend rates will be variable throughout these projects and highly dependent on the project’s phase.
The site geology is a key factor — we highly recommend conducting a feasibility study before beginning a project to assess the suitability of Class 6 injection at the proposed location. In addition, when the permit process begins, it’s important to front-load the site characterization efforts to minimize the uncertainty surrounding your site suitability.
Proactive stakeholder engagement surrounding your project is more likely to help lead your project to success. Developing outreach plans help open and facilitate lines of communication with stakeholders, regulatory officials, and public and environmental advocate groups.
Use an iterative project approach – permitting is not a cookie-cutter but a site-specific process. Your early and thorough planning steps help create a feedback loop that will go on throughout the project’s life. It enables flexibility in implementing your approach.
Kacey Garber is an experienced groundwater project manager for active and closed industrial clients, including routine groundwater monitoring and statistical analyses; reports and permit applications; designing sampling and analysis plans; special groundwater studies; and conducting groundwater well construction planning and design. She has also been involved in PFAS work groups and publishes on the topics of UIC and geologic sequestration. Ms. Garber has a Masters degree in Geoscience.
Meet Catelyn Scholwinski, SMM Director, and Stephanie Watson, SMM Vice Director, during an hour-long webinar where we’ll chat about how they got to where they’re at today, their advice for young professionals, and their predictions for our industry. Come ready to ask questions and get to know who is leading the SWANA SMM Technical Division!
SWANA has Technical Divisions that focus on specific solutions for the waste industry. Sustainable Materials Management (SMM) is a very important one. The Division has an upcoming event that is a great opportunity for young professionals interested in more sustainable reuse, recycling, and resource management.
SCS’s own Kelli Farmer is SWANA’s SMM Young Professional Representative. If you want to speak with the men and women on SCS’s Sustainable Materials Management teams, please get in touch with us at .
SCS Engineers is leading the charge to sustainable materials management through innovative policies, programs, and infrastructure that increase diversion, reduce contamination, recycle more materials, and manage costs. SCS offers comprehensive services to assist in achieving your SMM goals and reducing your carbon footprint. We offer technical expertise and the financial, regulatory, and educational skills to develop cost-effective and sustainable programs.
Meet Catelyn Scholwinski, SMM Director, and Stephanie Watson, SMM Vice Director, during an hour-long webinar where we’ll chat about how they got to where they’re at today, their advice for YPs, and their predictions for our industry. Come ready to ask questions and get to know who is leading the SWANA SMM Technical Division!
SWANA has Technical Divisions that focus on specific solutions for the waste industry. Sustainable Materials Management (SMM) is a very important one. The Division has an upcoming event that is a great opportunity for young professionals interested in more sustainable reuse, recycling, and resource management.
SCS Engineers is leading the charge to sustainable materials management through innovative policies, programs, and infrastructure that increase diversion, reduce contamination, recycle more materials, and manage costs. SCS offers comprehensive services to assist in achieving your SMM goals and reducing your carbon footprint. We offer technical expertise and the financial, regulatory, and educational skills to develop cost-effective and sustainable programs. SCS’s own Kelli Farmer is SWANA’s SMM Young Professional Representative.
If you are interested in an environmental career that can impact climate change for the good – this is it! Many types of positions are open now.
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