SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at http://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin summarizes the
This Bulletin provides information on these revisions, as follows:
Learn more about Waste Management’s Award at minute 30:54 of the video conference recording. Congratulations to the Waste Management Team!
The Ignition Firebrand Awards recognize system integrators such as SCS Engineers and industrial firms for their use of technology to create innovative solutions.
Today at the virtual Ignition Community Conference, Waste Management (WM) is accepting the 2020 Firebrand Award for its landfill technology and automation platform advances. The Company designed an internal solution then contracted with SCS Engineers’ RMC Practice, and Vertech Industrial Solutions to deploy WM’s new innovative ‘Connected Landfills’ pilot.
“Waste Management is excited to be recognized for our innovative work and use of new technologies,” said Bryan Tindell, vice president of disposal operations at Waste Management. “Striving for the most innovative and advanced technology in the world of waste helps ensure we are able to continue providing essential services for residents, customers and our communities. The use of advanced technology has also introduced new ways of working for our employees, further elevating their daily experience and streamlining our processes.”
WM’s Connected Landfills system was first piloted at the West Edmonton Landfill in Edmonton, Alberta, Canada. The pilot proved to simplify workflows, equipping landfill assets with internet-connected devices and sensors. Technicians are able to review data remotely via dashboards on mobile devices, allowing them to monitor changes, make decisions and even directly interact with equipment with the push of a button. With less time spent in transit, landfill employees will be able to spend more time managing landfills’ productivity and health.
“The integration of remote monitoring and control helps make landfill operations more efficient, sustainable, and creates a safer environment for landfill staff and the surrounding community,” said Dave Hostetter, regional manager of SCS RMC®. “That the innovation is being recognized as well is gratifying.”
This design and integration advances WM’s existing environmental management platform by increasing worker safety, the user experience, and running the landfill systems efficiently. It also supports Waste Management’s commitment to ensuring public safety and environmental protection for landfill staff and the surrounding community. Landfills, and the municipalities and companies that operate landfills use sophisticated technology to manage the complex environmental systems that keep citizens and the air, water, and soil surrounding landfills healthy. Ongoing collection of data from these assets, often collected by checking meters positioned throughout landfill sites, is essential for landfills’ safe operation.
Waste Management operates the largest network of landfills in the industry, managing the disposal of almost 100 million tons of waste every year at over 250 sites across Canada and the US. Based on the pilot’s success, WM plans to expand the Connected Landfills system to other sites throughout North America.
About Waste Management
Waste Management, based in Houston, Texas, is the leading provider of comprehensive waste management environmental services in North America. Through its subsidiaries, the Company provides collection, transfer, disposal services, and recycling and resource recovery. It is also a leading developer, operator and owner of landfill gas-to-energy facilities in the United States. The Company’s customers include residential, commercial, industrial, and municipal customers throughout North America. To learn more information about Waste Management, www.wm.com.
About SCS Engineers
SCS Engineers’ environmental solutions and technology are a direct result of our experience and dedication to |solid waste management and other industries responsible for safeguarding the environment while delivering products and services. For more information about SCS, please visit our website at scsengineers.com or watch our 50th Anniversary video.
Navigating the Permitting Process for CCR Impoundment Closures and Groundwater Monitoring Systems
Join us on Monday, July 27 from noon to 2 p.m. CDT to learn how SCS Engineers helps electric utilities overcome permitting obstacles at CCR impoundments and landfills. We offer the service nationwide.
Using case studies, we’ll highlight the permitting process and the keys to how electric utilities overcame obstacles to achieve the results they needed.
What you can expect to learn?
Registration and USWAG conference information here. This year’s event is a series of webinars USWAG is offering at no additional charge for members and affiliates.
Regulators are offering some regulatory flexibility on a case-by-case basis for special situations that are unavoidable and, most importantly, do not pose a risk to human health or the environment.
If you find that your business has been unable to remain in compliance, follow the four steps Cheryl Moran suggests in her most recent article. Cheryl provides examples from Illinois, Indiana, and Wisconsin. Remember, policies may be updated or terminated at any time; so, be sure to visit your appropriate state websites regularly or contact your SCS Project Manager for advice.
About the Author: Cheryl Moran is a Project Manager at SCS Engineers with more than 25 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and develops air, water, and waste management solutions; EPCRA; environmental compliance audits and navigating discretionary enforcement; and sustainability programs. For any of our 50 states contact or our nearest office.
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website.
Our most recent Bulletin summarizes the 2020 Virginia State Plan for New Landfill EG approved by the USEPA on June 23, 2020.
The Environmental Protection Agency (EPA) approved a Clean Air Act (CAA) section 111(d) plan submitted by the Virginia Department of Environmental Quality (VADEQ). This plan was submitted to fulfill the requirements of the CAA and in response to EPA’s promulgation of Emissions Guidelines and Compliance Times for municipal solid waste (MSW) landfills.
The Virginia plan establishes emission limits for existing MSW landfills and provides for the implementation and enforcement of those limits. Highlights of the plan are explained in a newly published SCS Technical Bulletin.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed.
On March 26, the U.S. Environmental Protection Agency (USEPA) finalized amendments to the 2003 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste Landfills. The NESHAP rules affect air permits and landfill gas system operating requirements for most active landfills. Read the Technical Bulletin here.
Some permittees welcome the revised wellhead operational standards, but other changes including additional monitoring requirements for wells operating at higher temperatures, and correction and clarification of Startup, Shutdown, and Malfunction (SSM) requirements are creating confusion. Landfill owners have an 18-month phase-in period before full compliance with the NESHAP requirements, so now is the time to unravel the confusing language between NESHAP rules and existing New Source Performance Standards (NSPS) rules (Subpart WWW and Subpart XXX).
SCS Engineers and SWANA are presenting a series of webinars and resources to help landfill owners and operators untangle the confusing permit phraseologies and implications created when state agencies with air permitting authority incorporate the NESHAP requirements into Title V operating permit renewals and construction permits.
Tune in for advice on Wednesday, June 24, 3:40 PM – 4:15 PM:
SWANAPalooza 2020 Virtual Conference — Navigating the Maze of Federal Air Quality Regulations for Landfills with Pat Sullivan. Pat and other presenters will discuss the EPA’s landfill regulations, including NSPS, NESHAP, and Emission Guidelines.
Tune in earlier for other key presentations including:
The environmental reporting season is just around the corner. Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.
The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry. Contact us at or find a professional like Ann, nearest you.
Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Article published in the January 2020 edition of Waste Advantage Magazine.
At the Federal level, GHG emission reporting has become part of the standard regulatory requirements; however, on the west coast, GHG programs continue to develop and evolve from reporting to reduction programs beyond federal requirements. Solid waste facilities can be impacted by all of these reporting mechanisms directly as a landfill located in the state in question, opting in for C&T as part of the LCFS in California, or in limbo, as the courts work out the legality of Washington’s Clean Air Act. More stringent federal GHG requirements are unlikely with the current administration, however, that could change with the 2020 election. In general, GHG rules and legislation keep developing and updating to account for and reduce GHG emissions.
Cassandra Drotman Farrant is Project Manager with SCS Engineers. She has nine years of experience in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. Cassandra has participated in many GHG verification projects throughout the U.S. and has completed approximately 70 Phase I Environmental Assessments (ESAs) in California, Oregon, and Washington. Phase I projects included research and review of geologic and hydrogeologic conditions at project sites and in the surrounding areas and evaluating the potential for soil and groundwater contamination from on and offsite sources. Cassandra has completed emissions estimates and inventories and has prepared numerous permit-to-construct/operate permit applications. She prepares compliance reports, which includes reviewing and maintaining records and regulatory deadlines.
SCS Engineers provides engineering, consulting, operations and monitoring services to report and reduce greenhouse gas emissions. Select a service category to learn more.
REPRINT FROM THE EPA PRESS RELEASE
EPA Finds That Financial Risks from Petroleum and Coal Products Manufacturing Industry Does Not Warrant Additional Federal Requirements
WASHINGTON (Dec. 4, 2019) — Today, the U.S. Environmental Protection Agency (EPA) is proposing to not impose burdensome and potentially duplicative financial responsibility requirements for the petroleum and coal products manufacturing industry (the industrial sector that transforms crude petroleum and coal into usable products) because the financial risk to the federal government from those facilities is already addressed by various existing federal and state technical and financial requirements and modern material management practices. EPA’s proposed action would not drop existing federal requirements, rather it is a proposal to not impose additional requirements.
“After a thorough evaluation, EPA has determined that the petroleum and coal manufacturing industry’s current practices, along with existing federal and state regulations, adequately address potential financial risks to the federal government and American taxpayer,” said EPA Administrator Andrew Wheeler. “As part of President Trump’s commitment to protecting our environment and growing our economy, we are committed to responsible regulation while not imposing additional and unnecessary requirements on key sectors of the economy when the current regulatory framework is working.”
In the 39 years since the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted, a comprehensive regulatory framework has developed. Existing monitoring and operation standards have consistently worked over time to decrease the risk in this industry that if a hazardous waste cleanup is needed, the federal government will have to bear the cost of cleanup.
Further, this proposed finding does not affect, limit, or restrict EPA’s current authority to take a response action or enforcement action under CERCLA at any facility in this industry, to include requirements for financial responsibility as part of such response action, or to take appropriate action under various other federal environmental statutes that may apply to individual facilities, such as the Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, and Toxic Substances Control Act. These existing regulations, including financial responsibility requirements, continue to apply to facilities in this industry.
This proposal is consistent with the analysis EPA undertook in developing its final action for the hard rock mining industry. In that case, EPA’s approach was unanimously upheld by the D.C. Circuit Court of Appeals in July 2019. EPA has evaluated the degree and duration of risk of the possible cost to cover the cleanup of hazardous substance releases associated with the production, transportation, treatment, storage, or disposal of hazardous substances in the petroleum and coal products manufacturing industry. EPA also examined the industry’s economic trends and the financial health of the sector and found the industry to be in a relatively stable financial position with low default risk. EPA’s evaluation showed that existing regulatory programs and voluntary practices reduce the need for federally financed response action at facilities in this industry.
Section 108(b) of CERCLA, also known as Superfund, directs EPA to develop regulations requiring classes of facilities to establish and maintain evidence of financial responsibility to cover the costs associated with releases or threatened releases of hazardous substances from their facilities.
In December 2016, EPA described its plan to consider financial requirements under CERCLA for the electric power industry, the petroleum and coal products manufacturing industry, and the chemical manufacturing industry. On July 2, 2019, EPA proposed to not issue financial responsibility requirements for the electric power industry. EPA is currently working on a proposal for the chemical manufacturing industry.
Today’s proposal for the petroleum and coal industry will be published in the Federal Register, and EPA invites stakeholders and the public to provide comments during the 60-day public comment period.
For more information, visit: https://www.epa.gov/superfund/superfund-financial-responsibility, or contact SCS Engineers at for help.
Before the Court: EPA admits that it has failed to meet its nondiscretionary obligations to implement the Landfill Emissions Guidelines, as compelled by the CAA. The only questions before the Court were whether the Plaintiffs have standing and, if so, how long to give EPA to comply with its overdue nondiscretionary duties under the Landfill Emissions Guidelines. The Plaintiffs are the States of Illinois, Maryland, New Mexico, Oregon, Rhode Island, California, Vermont, and the Commonwealth of Pennsylvania.
Ruling: Plaintiffs have standing, and the EPA must approve existing submitted plans by September 6 and issue the federal plan by November 6.
Impact on Landfill Owners/Operators: This will create some confusion, as landfills will be working on getting revised rules in place while at the same time start complying with the old EG rule. We are already doing that with XXX sites, but this ruling adds complexity. If EPA keeps to the schedule and we have final approved revised rules by March 2020, landfills won’t have to do as much under the old rules before new ones take effect.
Contact your SCS Project Manager for more information, email us at , or follow SCS on your preferred social media.