The U.S. Environmental Protection Agency (EPA) has launched a broad-ranging PFAS Strategic Roadmap aimed at effectively managing Per- and Polyfluoroalkyl Substances (PFAS) in diverse environments, including air, water, soil, and wastewater systems. This roadmap underscores the EPA’s commitment to addressing the challenges posed by PFAS, a group of synthetic chemicals extensively used in various industrial and consumer products for their resistance to heat, water, and oil.
While over 10,000 PFAS variants are known, only a small proportion are currently under regulatory scrutiny, with the number of regulated PFAS varying across countries and regions.
In the United States, the EPA concentrates regulatory and monitoring efforts on a select group of PFAS, primarily due to the scientific complexity of these compounds, analytical limitations, limited toxicity data, and the vast diversity of PFAS chemicals.
This SCS Engineers blog series, Navigating PFAS Compliance, delves into the regulations, management, and monitoring of PFAS at municipal solid waste (MSW) landfills, addressing environmental mediums including air, groundwater, wastewater (i.e., leachate), soil, and waste.
Landfill Regulations and Revisions Anticipated in 2024
Landfills are subject to various regulations, notably under the Resource Conservation and Recovery Act (RCRA) for both hazardous and non-hazardous waste, the Clean Air Act (CAA) for air emissions, and the Clean Water Act (CWA) for water resource protection. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, also plays a role in addressing contaminated landfill sites, particularly those that pre-date the promulgation of the RCRA Subtitle D program in the early 1990s.
Currently, RCRA does not have specific PFAS regulations for MSW landfills. However, the EPA is developing a rule to classify certain PFAS as “hazardous constituents” under RCRA. We anticipate the proposal in 2024.
Additionally, the EPA has already proposed listing two PFAS constituents – Perfluorooctanoic acid (PFOA) and Perfluorooctanesulfonic acid (PFOS) as hazardous substances under CERCLA, a move that could impact environmental cleanup and liability, particularly for landfills with releases impacting groundwater and adjacent areas. We anticipate the final CERCLA hazardous substances listing in 2024.
The EPA is also revising Effluent Limitation Guidelines to limit PFAS discharges into municipal wastewater treatment facilities. These include amending the Landfills Point Source Category ELGs under Effluent Guidelines Program Plan 15.
While research directly characterizing PFAS in landfill gas is limited, the presence of semi-volatile PFAS in municipal solid waste suggests their occurrence in landfill gas. The EPA is formulating regulations to control PFAS air emissions from multiple sources (e.g., LFG systems), with specific details yet to be fully established.
Federal and State Policies Evolve
The regulatory landscape for PFAS is swiftly evolving, with numerous states setting or updating PFAS standards to address emerging concerns and research findings. States like Alaska, Colorado, Delaware, Florida, Illinois, Indiana, Iowa, Maine, Michigan, Minnesota, Montana, Nevada, North Carolina, Pennsylvania, Rhode Island, Texas, Vermont, and Washington have implemented various PFAS standards.
Managing PFAS in landfills requires a comprehensive approach that includes advanced treatment technologies, compliance with changing regulations, continuous monitoring of the regulatory landscape, and, where necessary, remediation.
This SCS blog series will explore and report PFAS issues across each regulatory category impacting MSW landfills, offering insights into compliance, management, and regulatory aspects. Feel free to contact the authors with questions or comments; we’re here to help.
Additional Resources:
About the Authors: Connect with our authors and experts at
Jeff Marshall, PE, is a Vice President of SCS Engineers, Environmental Services Practice Leader for SCS offices in the Mid-Atlantic region, and our National Expert on Emerging Contaminants and Innovative Technologies. His four decades of experience include a diversified background in project engineering and management, emphasizing environmental chemistry, hazardous materials, waste and human health risk issues. Focus areas include environmental permitting, regulatory compliance, and hazardous materials treatment and remediation. He is a licensed professional engineer in Virginia, Maryland, West Virginia, North Carolina, and South Carolina.
Kacey Garber, PG, is presenting on Wednesday, February 28th (8:30 am – 9:00 am, Plaza).
Kacey will answer the question, How Might Co-Mingling UIC Waste Plumes Affect Class I UIC Operations and the Area of Review?
Class I UIC wells may be utilized to dispose of fluid wastes within deep geologic units, such as depleted hydrocarbon reservoirs or saline aquifers. Class I UIC wells may be located in the vicinity of other injection wells associated with disposal and/or hydrocarbon production. Injecting fluids leads to mixing with and displacement of native fluids within the reservoir. Because water is relatively incompressible, the mixing and displacement of fluids lead to a buildup of pressure within the reservoir. The magnitude of this pressure buildup is dependent on several factors, including the porosity and permeability of the reservoir, the density and viscosity of both the previous and present-day injectate and native fluids, and the thickness and lateral extent of the reservoir.
Elevated reservoir pressures resulting from injection can allow fluids to migrate upwards through open or improperly plugged artificial penetrations and/or fractures of the reservoir or confining zones, either of which would endanger overlying aquifers. As a result, agencies require Class I UIC permit applications to include calculations or modeling to assess what pressure thresholds would lead to aquifer endangerment. Many of these calculations do not allow realistic predictions of pressure buildup or plume extent in situations where co-mingling of waste plumes may occur. In this presentation, we assess the utility of computational flow modeling for complex injection scenarios where the co-mingling of waste plumes from neighboring operations might influence pressure buildup and overall plume extent.
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.
Additional Resources:
SCS Engineers is participating in the Georgia Tech ASCE/AEES 2024 Spring Civil and Environmental Engineering Career Fair on Thursday, February 1st, 2024.
Each year, Georgia Tech American Society of Civil Engineers (ASCE) and Association of Environmental Engineers and Scientists (AEES) co-host the Spring Civil and Environmental Engineering (CEE) Career Fair. This event is a great opportunity for all students and alumni to connect with a diverse array of employers, from corporations to nonprofits, for internships, part-time, and full-time positions. For company representatives who will be attending the career fair, this link contains valuable logistical information like times, parking, and table space details.
SCS is an employee-owned, award-winning environmental engineering, consulting, and construction firm with offices nationwide. We are seeking a wide variety of dedicated, hard-working professionals with Science, Technology, Engineering, and Mathematics (STEM) backgrounds.
Wastewater treatment is crucial to safeguard our water resources and the environment. Additionally, recycling wastewater is an excellent way to conserve this valuable resource, especially important for citizens and industry in the near future. At SCS Engineers, we specialize in the sustainable collection, treatment, and reuse of wastewater for municipalities and industries—our Landfill Leachate and Industrial Wastewater Treatment practice designs and implements these solutions.
SCS is excited to announce that Kerim Temel, PE, has joined the practice as a project director and wastewater treatment services leader. Based in Virginia Beach, Virginia, Kerim will provide technical project support and guidance for municipal and industrial wastewater treatment, landfill leachate treatment, groundwater remediation, and treatment systems operations and maintenance (O&M) across SCS. He has extensive experience treating complex wastewater from various industries, including landfills, pharmaceuticals, food and beverages, and chemical manufacturers. He has expertise in treating conventional and emerging contaminants such as Perfluoroalkyl Substances—PFAS. Temel’s skills include alternative evaluations, characterization, treatability testing, process design, confirmation testing, system evaluations, startup and training, and system optimization and troubleshooting.
Josh Strickland has recently joined SCS Engineers as a project professional based in Mobile, Alabama. He holds an academic background in chemical engineering and has gained experience in the oil and gas, manufacturing, and solid waste industries. Strickland primarily focuses on process engineering and supports project execution through process and mechanical design improvements. These improvements significantly enhance safety, design, production, processing, sizing, and equipment procurements while positively impacting collaboration.
SCS has a proven history of helping clients overcome their wastewater management issues. Treating and reusing wastewater is complex, but it is essential for many of our clients’ operations, sustainability objectives, and financial performance. With the addition of Kerim and Josh to SCS’s team, we have strengthened our technical expertise and capacity to tackle these challenges. ~ Nathan, Hamm, senior vice president and SCS’s national expert on Liquids Management.
This protocol applies to greenhouse gas reduction projects that divert eligible organic waste or agro-industrial wastewater streams that otherwise would have gone to uncontrolled anaerobic storage, treatment, and disposal systems (solid waste landfills, onsite anaerobic wastewater treatment facilities, etc.).
Projects that involve co-digestion of eligible organic waste streams with livestock manure are also eligible if they comply with the Livestock Project Protocol, diverting waste to a biogas control system (BCS). The protocol accepts several technologies, including:
Project Eligibility
The protocol stipulates the following requirements:
Project Exclusions
Protocol excludes the following activities:
Project Outcomes
A project is eligible to receive credits for ten years from the start date or until project activity is required by law. Applications for a second 10-year eligibility period are available. Only two AD facilities have registered with the Climate Action Reserve (CAR). CAR has awarded these projects a total of 224,655 CRTs, valued at approximately $700,000. In 2022, CAR awarded 22,257 CRTs to these projects. At a market price of $3.00/CRT, 22,257 CRTs have a value of $66,771.
Credit Feasibility
Understanding the technology and navigating protocol requirements can take time and effort. That’s where we come in. Contact SCS Engineers at or Greg McCarron on LinkedIn to learn how your project may qualify.
Additional Resources
SCS has a group of national experts working with all offices in North America to provide in-depth knowledge based on decades of experience supporting clients’ environmental needs. These resourceful people provide a wealth of information and guidance to support sustainable solutions in the industries SCS works in and with other professionals. Clients depend on the combination of SCS professional expertise, SCS leadership, and our roster of National Experts who consistently bring value to each solution. With the expanded leadership, SCS’s third generation can create even more sustainable solutions to environmental challenges. The firm announces its newest national experts as follows:
Anaerobic Digestion – Erik Anderson, PhD, is a Senior Project Manager. He has 14 years of engineering and process design experience in the renewable fuels sector, including anaerobic digestion, pyrolysis to syn-gas generation, and zero-liquid discharge technologies. He has worked on projects from initial concept development through front-end engineering design and construction management. His work includes modeling renewable energy technologies for economic comparison or life-cycle analysis. He is the inventor of several U.S. patents related to bioenergy and served as commissioner on the National Biodiesel Accreditation Committee from 2014-2021.
Brownfields Grants – Melissa Schick’s expertise includes preparing successful brownfields grant applications, helping public and private-sector clients navigate state and federal brownfields redevelopment and voluntary cleanup programs and closeout requirements, implementing and completing brownfields redevelopment projects, coordinating and communicating with all stakeholders.
Clean Air Act & NSPS – Josh Roth, PE, is a Project Director with the Landfill Gas (LFG) practice, serving on many LFG engineering projects involving LFG remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects. Roth regularly publishes and presents at industry and regulatory events, often appearing in client webinars, and leads one of SCS’s internal “University” training sessions monthly.
Elevated Temperature Landfills – Bob Dick, PE, works on civil and environmental engineering projects related to solid waste management. He has worked on over 25 major landfill multi-task assignments and performed over 150 landfill gas projects – some of the toughest in the US. His work involves landfill gas migration control, odor control, emissions control, Clean Air Act compliance, energy recovery and utilization, and carbon credit monetization. Dick is part of the SCS team that developed technical standards for the largest waste operator in the U.S. to implement in active and future disposal cells to prevent the formation of ETLF conditions in landfills. He incorporates these standards into the best management practices of landfill management teams globally.
Odor Management – Paul Schafer. Many of today’s waste management strategies and facilities lower GHGs. They, along with agricultural production, can emit odors. SCS has two National Experts to address industrial needs. Schafer leads Ambient Air Monitoring Services and plays key roles in significant national monitoring efforts. He has in-depth experience in interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and odor assessments, as well as with federal and state agencies regarding monitoring programs and air quality impact assessments, particularly for agriculture.
Odor Management – Patrick Sullivan, BCES, CPP, REPA. Sullivan is SCS’s National Expert for Clean Air Act (CAA) programs and leads the firm’s GHG, Sustainability, and CAA services. With over three decades of experience, he is often sought after to mitigate odors and analyze potential exposure for solid waste and industrial facilities. Sullivan is also a Senior Vice President and Principal-in-Charge for air quality permitting and compliance projects, GHG emissions, and climate change. Pat is a Harvard-degreed scientist, a Registered Environmental Property Assessor, Board Certified Environmental Scientist, a Certified Permitting Professional in the South Coast Air Quality Management District, and an accredited Lead Verifier under the California Air Resources Board (CARB) AB 32 Greenhouse Gas (GHG) programs.
Sustainable Planning – Steven Stewart, PE, PMP. Stewart is responsible for project development and client account manager for those with a sustainability focus. He has more than two decades of experience within the Environmental Consulting and Manufacturing Industry, providing strategic thinking related to project planning, regulatory strategy, and developing sustainability initiatives. Stewart leads projects related to energy efficiency measures, GHG reduction, carbon sequestration, water reuse and stewardship, and solid waste minimization and recycling programs. He has managed and performed permitting and compliance audits, developed environmental management systems, long-term environmental planning, and environmental sustainability capital projects. His background includes serving as Environmental Manager and Capital Projects Portfolio manager at a large steel manufacturing facility.
Over the years, SCS expanded and hired many talented people. They guide the firm, maintaining the founders’ focus and culture of adopting their clients’ environmental challenges as their own and fostering a culture of success for employees and communities.
The firm has won multiple awards for helping clients minimize waste generation, effectively managing recycling, collection, and disposal operations, renewable energy, safely cleaning up contaminated properties, protecting wastewater and groundwater, and cutting GHG emissions.
These employee-owners are most proud of the difference they make for their clients and communities as trusted partners. SCS clients entrust the firm with managing more than 35 million metric tons of anthropogenic CO2e greenhouse gases yearly. SCS collects and beneficially uses or destroys enough to offset greenhouse gas emissions from 7.4 million passenger cars annually. That’s more than any other environmental firm in North America.
Nicole Vogelpohl and Eva Luu attended the “Meet the Regulators” event hosted by A&WMA’s Golden West Chapter at the law firm Holland & Knight in San Francisco. It was an informative event where panelists Dr. Meredith Bauer, Hy Hinojosa, and Lisa Fasano, in for Viet Tran, from the Bay Area Air Quality Management District (BAAQMD), spoke about upcoming priorities, new organizational changes, current organizational issues, and project accomplishments. The three have recently been appointed new deputy executive officer positions at BAAQMD. They are open to taking things in a new direction regarding the permit process, communications with the public, and implementing new and upcoming methodologies for emerging analytical measurement technologies.
Environmental Justice and Air Quality
The panel discussed how, as we’ve learned and made continuous progress in air quality and local emissions reductions over the years, ozone (O3) is now less of a concern (for the Bay Area) compared to PM2.5, which now takes higher precedence as a pollutant of concern. Dr. Bauer and Lisa Fasano mentioned that in the grand scheme of things, we live in a region of great air quality; however, they acknowledge that while the greater San Francisco Bay Area has good air quality as a whole, there are always pockets of localized air pollution that need addressing. Areas specifically pointed out were marginalized communities, such as Bayview/Hunter’s Point and West Oakland. Coincidentally, SCS is currently involved in a project related to the SF Fire Department’s Training Facility moving from Treasure Island to Hunter’s Point. The goal is to ensure the air quality during their training burns will not have long-term downwind effects on the community.
Thorough Discussion Amongst the Panelists and Attendees — Permitting Backlog Issue
The current permitting system needs to be faster, and the backlog of processed permit applications poses challenges for new clients. Attendees expressed frustration and shared testimonies about their clients moving to different states due to the extensive permitting backlog and timely process, which has ultimately halted the emersion of some new regulatory technology and projects in the state. The regulators understand the current system needs reworking and prioritizing to ease and reduce the turnover time of the permit process.
Enlightening and Enjoyable
Hearing the regulators speak passionately about their roles, goals, and investment in the organization was truly pleasing. Thanks to Pat Sullivan for knowing and having worked with everyone we talked to; everyone said hi and spoke highly of you! At “Meet the Regulators,” we connected with stakeholders from local consulting firms, attendees from the petroleum, tech, and waste management industries, and regulators – or, as Dr. Bauer renamed the group, the communicators, to help bridge the gap between the governing board and the general public.
Additional Resources
In the realm of global sustainable development, engineering stands as a crucial pillar, driving innovation and progress. Women, representing half of the world’s population, play a pivotal role in this narrative, bringing diverse perspectives and innovative solutions to the forefront. One such trailblazer in the field is Anastasia Welch, whose contributions at SCS Engineers exemplify the impact women engineers can have on shaping a sustainable future.
With a keen eye for detail and a passion for environmental sustainability, women like Anastasia drive positive change in the waste industry. Here’s her journey, which we hope will inspire you.
Building Professional Experience
As a Vice President/Project Director, Ms. Welch utilizes her civil engineering background to affect solid waste-related projects in numerous states for both municipal and private clients. Throughout her career, Anastasia has focused on solid waste-related solutions ranging from design and compliance to planning. As a solid waste practice leader in the Central Region, Anastasia leverages her experience across the company to bring the appropriate personnel and work efforts to meet clients’ expectations and needs.
This month, she achieved a milestone in her career with her promotion to the Business Unit Director for SCS’ Central Region. She brings technical expertise and a unique perspective that enriches her team’s problem-solving capabilities. By influencing industry standards and promoting responsible environmental practices throughout the firm, her leadership extends beyond the Central Business Unit.
Project Experience
Mrs. Welch enjoys assisting her clients to help them meet their long-term goals. Anastasia is passionate about landfills and the waste systems that serve our communities. As of 2020, she is the Co-Chair of SWANA’s Landfill Re-Branding Committee, focusing on changing how the public views landfills. More recently, she has become much more involved with industrial clients, assisting them with their multimedia permitting and compliance needs.
Anastasia appreciates the details of technical compliance regulations by putting the pieces together, whether for a landfill or an industrial manufacturing facility. She excels by protecting our environment in a responsible way that still allows businesses to thrive.
Her specialty services areas include landfill design, transfer stations, solid waste planning, industrial facilities support, gas, stormwater, and environmental & industrial compliance.
Demonstrating a Passion for Environmental Engineering and Leadership
Anastasia’s dedication to details has proven instrumental in navigating the complex landscape of waste management and landfill design. Women engineers like Anastasia bring a holistic approach to problem-solving, ensuring that solutions are sound and environmentally responsible.
Anastasia’s role as Co-Chair of SWANA’s Landfill Re-Branding Committee exemplifies SCS Engineers’ proactive stance in reshaping industry narratives. By actively working to change public perceptions of landfills, she demonstrates the transformative power of combining technical expertise with effective communication and education.
Publications and Presentations
Anastasia actively contributes to the field through various publications and presentations, showcasing and sharing successful solutions. Noteworthy publications include “Developing a Master Plan for the City of Kirkwood, MO” and “Systematic Pathways to a Sustainable Waste Business.” Her presentations at conferences such as the Global Waste Management Symposium and the Missouri Waste Control Coalition Conference reflect her dedication to knowledge sharing and staying at the forefront of industry trends.
Education and Professional Licenses
Anastasia holds a B.S. in Civil and Environmental Engineering from the University of Missouri, Columbia, graduating in 2000. She is a licensed Professional Engineer in Kansas, Missouri, Iowa, and North Dakota, showcasing her commitment to maintaining high professional standards.
The Transformative Power of Women in Environmental Engineering
Anastasia’s journey is a story of dedication, expertise, and leadership, from her educational background to her technical and managerial experience. Anastasia demonstrates a passion for environmental sustainability and a commitment to excellence.
As we celebrate the achievements of women like Anastasia, we recognize the collective impact women engineers have on achieving sustainable development goals. Their contributions go beyond technical expertise; each brings a fresh perspective, resilience, and a commitment to leaving a positive mark on the world. By fostering inclusivity, encouraging mentorship, and championing diversity, we pave the way for more engineering women to be architects of sustainable progress. The journey of women in engineering and as environmental consultants, exemplified by Anastasia, is a testament to the endless possibilities when talent knows no gender or color.
SCS Engineers is an exciting, challenging, rewarding place to work that is nationally recognized as an industry leader. Join us in supporting businesses and communities throughout North America.
Carbon management often takes a holistic approach, combining one or more environmental solutions. The CO2 experts at SCS Engineers recommend looking at Graphyte’s hybrid technology approach for carbon casting, a new approach to carbon removal that leverages readily available biomass. The solution is backed and incubated by Bill Gates’ Breakthrough Energy Ventures. Here’s how it works…
Learn more about sustainable carbon management, carbon casting, carbon sequestration, and carbon reduction verification.
SCS Engineers announces that the firm’s Board of Directors elected Doug Doerr as President and Chief Executive Officer. James J. Walsh, the current President and CEO, will turn over his responsibilities to Doerr on January 1, 2024.
Doerr, a Senior Vice President, has over three decades of professional engineering experience spanning the firm’s solid waste and environmental services practices. He brings strategic direction and operations experience as SCS’s geographically largest Business Unit Director. Doerr also serves on SCS’s Board of Directors and was one of the founding principals of Aquaterra Environmental Solutions, Inc., which merged with SCS in 2013.
A Professional Engineer in six states, Doerr earned his Bachelor of Science in Civil Engineering at the University of Nebraska, Lincoln, and his Master of Business Administration at the University of Kansas. He serves clients in North America by providing technical expertise, primarily in the solid waste management and utility sectors.
As an engineer and consultant, Doerr prides himself on providing environmental solutions to address clients’ technical and regulatory challenges by understanding the business, economic, and social drivers that frame each challenge. Over his career, he has successfully implemented hundreds of environmental solutions that involve studies, permitting, compliance, and design across multiple market sectors for public and private clients.
“Our deep bench of engineers, scientists, consulting professionals, and environmental technicians are employee-owners who drive SCS as one company, keeping us sustainable for over 50 years. From our client’s perspective, our stability and holistic expertise bring a wealth of resources to achieve their goals,” says Doerr.
Walsh will continue to serve as Chair of the Board of Directors and assist Doerr as he transitions into the CEO role. Walsh also plans to spend more time on technical and client work as an expert witness, an authority on elevated temperature landfills, and an expert in the solid waste industry.
Under Walsh’s 22-year tenure, SCS Engineers and its specialty practices, SCS Field Services, SCS Energy, and SCS Tracer have grown tremendously. Walsh, senior executives, and the Board of Directors feel 2024 is an opportune time for the transition.
“We have a stellar reputation, we’re financially healthy, our Employee Stock Ownership Plan is strong, and we have the next generation of leadership ready to lead the company into the future,” states Walsh.
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver essential services and products. SCS Engineers has captured or beneficially used more greenhouse gases than any other environmental engineering firm in the U.S. Please visit our website for a greeting from our CEO elect, or watch our video to see what we can do for your business and community.
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