epa compliance

EPA Alternative Test Method for NESHAP MSW Landfill CO Monitoring in Landfill Gas Wells Approved | SCS Engineers

September 15, 2021

 

Approved
The EPA issued a newly approved alternative test method (ALT-143) for compliance with the enhanced monitoring provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for MSW Landfills (40 CFR 63 Subpart AAAA updated March 26, 2020). The approved alternative method instead of Method 10 allows for direct monitoring of CO at a landfill gas well using a portable gas analyzer. The NESHAP requires weekly monitoring of CO at the landfill gas well if the gas temperature is over 145F and the regulatory agency has approved no higher operating value under the NSPS/EG rules or NESHAPs. The Solid Waste Working Group (SWWG) coordinated with landfill gas meter manufacturers (QED, Elkins Earthworks) to prepare this method.

EIL approved sharing a flow chart and Excel file that can be used for monitoring/documentation purposes when using this approved alternative “field instrument method.” Don’t hesitate to get in touch with your SCS air emissions/compliance expert or contact us at for details.

EPA will post the alternative test method to the Broadly Applicable Approved Alternative Test Methods | US EPA website page. Take note that the hyperlink in EPA’s letter is out of date.

Pending Approval
The Solid Waste Working Group (SWWG) also submitted two alternative methods in lieu of Method 10 to EPA for approval using grab sample (canister, foil bag) and laboratory analysis, one with GC/FID and the other GC/TCD instrumentation. The SWWG coordinated with several national laboratories on the methods. EPA is completing its review of the two proposed methods, anticipating EPA approval before September 27, 2021, the effective date of the enhanced monitoring provisions.

 

 

 

 

 

Posted by Diane Samuels at 4:53 pm

Summer of Compliance – Articles, Videos, and Expert Advice at Your Fingertips

July 26, 2021

 

The EPA  and, in some cases, states are rolling out new emissions guidelines at least as stringent. The EPA estimates that the plans could cover about 1,600 landfills. These landfills are in 41 states, tribal entities, and the U.S. territories of Puerto Rico and the Virgin Islands.

MSW landfills without Gas Collection and Control Systems (GCCS) that reach a specific threshold will need to add these systems and have 30 months to install or update control systems to meet new standards.  As you’ve noticed by now, we’ve greatly oversimplified what is happening.

The new regulations and timetables are difficult to understand and untangle. SCS Engineers, in concert with SCS Field Services, have prepared resources to help during the transition period and afterward when landfills are likely to need more monitoring and measurement, thus creating millions of more bits of data to store, analyze, and report.

We hope you find these resources useful. We will be publishing more soon.

These resources may help you with future monitoring and maintenance:

  • VideoUsing GIS Technology on Landfills for efficient monitoring, maintenance, and compliance.
  • Waste Today Article: Landfill Operators discuss using eTools, a web-based application platform for landfill gas data.
  • EM Magazine: Remote Monitoring and Control and SCADA on landfills

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

NESHAP and NSPS/EG Transition Resources On-Demand at SCS Engineers

July 16, 2021

OOO, AAAA, NSPS, EG, and NESHAP alphabet soup.

 

Thank you to the many folks attending SCS’s live webinar on July 15th about managing the NESHAP, NSPS/EG transition period. As promised, we’ve created a library of resources for you to use and share with your colleagues.

 

These resources may help you with future monitoring and maintenance:

  • Video: Using GIS Technology on Landfills for efficient monitoring, maintenance, and compliance.
  • Web page: SCSeTools is a web-based application platform that collects, monitors, views, charts, graphs, and manages data.
  • Find an Expert: Search feature on our website to find assistance with the service area Clean Air Act.

 

We’re here to help. Please find an expert or contact us at .

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 4:33 pm

Two EPA Announcements – CWA Section 401 Certification Rule and the Risk Management Plan (RMP) Rule

June 1, 2021

epa rmp

 

May 27, 2021, from two separate U.S. Environmental Protection Agency (EPA) announcements:

EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule

Congress provided authority to states and Tribes under CWA Section 401 to protect the quality of their waters from adverse impacts resulting from federally licensed or permitted projects. Under Section 401, a federal agency may not issue a license or permit to conduct any activity that may result in any discharge into navigable waters unless the affected state or Tribe certifies that the discharge is in compliance with the Clean Water Act and state law, or waives certification.

EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule to restore the balance of state, Tribal, and federal authorities while retaining elements that support efficient and effective implementation of Section 401. While EPA engages with stakeholders and develops a revised rule, the 2020 rule will remain in place. The agency will continue listening to states and Tribes about their concerns with implementing the 2020 rule to evaluate potential administrative approaches to help address these near-term challenges.

The agency’s process of reconsidering and revising the 2020 CWA Section 401 Certification Rule will provide an opportunity for public and stakeholder input to inform the development of a proposed regulation, and will include sustained dialogue with state and Tribal co-regulator partners and local governments around these issues. EPA will begin a stakeholder engagement process in June to hear perspectives on this topic and how to move forward. More information will be available at: www.epa.gov/cwa-401.

 

EPA, Region 7, public listening sessions on the RMP Rule

Section 112(r) of the Clean Air Act Amendments requires EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. These regulations and guidance are in the Risk Management Plan (RMP) rule, which requires facilities using extremely hazardous substances to develop a Risk Management Plan that:

  • identifies the potential effects of a chemical accident,
  • identifies steps the facility is taking to prevent an accident, and
  • spells out emergency response procedures should an accident occur.

These plans provide information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community.

The Region 7 EPA announced two upcoming virtual public listening sessions on the Agency’s Risk Management Plan (RMP) rule. The RMP rule has been identified as an action for review under Executive Order 13990: Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis.

The listening sessions will give people the opportunity to present information, and provide comments or views pertaining to revisions made to the RMP rule since 2017. The Occupational Safety and Health Administration (OSHA) will also participate in the listening sessions and receive comments on their Process Safety Management (PSM) standard, which contains similar requirements to the RMP rule.

Virtual public listening sessions will be held on:

  • June 16, 2021, from 12:00 p.m. to 4:00 p.m. ET.
  • July 8, 2021, from 4:00 p.m. to 8:00 p.m. ET.

For more information on the public listening sessions:

https://www.epa.gov/rmp/forms/virtual-public-listening-sessions-risk-management-program-rule.

Submit written comments via the docket at: http://www.regulations.gov,  Docket ID: EPA-HQ-OLEM-2021-0312 until July 15, 2021.

EPA Region 7 serves Iowa, Kansas, Missouri, Nebraska, and Nine Tribal Nations.

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 11:17 am

SCS Engineers Technical Bulletin Published – Federal Plan for Landfill EG Rule – May 24, 2021

May 24, 2021

SCS Engineers Technical Bulletins

 

SCS Engineers periodically prepares SCS Technical Bulletins – short, clear summaries of U.S. Environmental Protection Agency (EPA) rules and plans. On May 21, 2021, the EPA published a Federal Plan to implement the new Emission Guideline (EG) rule for municipal solid waste (MSW) landfills. The Federal Plan is published under Title 40 of the Code of Federal Regulations (CFR) Part 62, Subpart OOO.

Read, share, download the Federal Plan for Landfill EG Rule Tech Bulletin here.

 

 

 

 

 

 

 

Posted by Diane Samuels at 5:22 pm

Regulatory Alert: MSW Landfills Federal Plan to Implement the Emission Guidelines (EG) and Compliance Times

May 14, 2021

SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients who have signed up to receive them. We also publish these on our website and social media accounts as well.

 

(40 CFR Part 60, Subpart OOO)

EPA is submitting a pre-publication copy of the final MSW Landfills Federal Plan to implement the Emission Guidelines (EG) and Compliance Times issued on May 10, 2021. The Final Plan becomes effective 30 days after publication in the Federal Register, impacting any remaining landfills without approved EG Cf rules.

EPA’s federal plan includes an inventory of designated facilities and an estimate of emissions from those designated facilities. The Agency estimates 1,590 landfills will potentially be covered in 42 states and the US territories of Puerto Rico and the Virgin Islands, and one tribal entity.

SCS Engineers is preparing a Technical Bulletin for distribution to our mailing list and on social media. The Bulletin will consolidate 133 pages into several pages highlighting significant dates and impacts for you.

 

EPA Actions: Final Federal Plan Requirements for Municipal Solid Waste Landfills

 

Affected are MSW landfills that commenced construction on or before July 17, 2014, and have not been modified or reconstructed since July 17, 2014.

EPA is implementing emission guideline requirements for existing MSW landfills located in states and Indian country where state plans or tribal plans are not currently in effect because they were not submitted or approved.

 

The Final 2016 Emission Guidelines for MSW Landfills require existing landfills that reach a landfill gas emissions threshold of 34 metric tons of nonmethane organic compounds (NMOC) or more per year to install a system to collect and control landfill gas (GCCS).

It also implements the emission limits, compliance schedules, testing, monitoring, reporting and recordkeeping requirements established in the Emission Guidelines for MSW Landfills.

Unless the landfill is a legacy controlled landfill, owners or operators of MSW landfills subject to the MSW Landfills Federal Plan must submit a design capacity report within 90 days after the effective date of the Federal plan (40 CFR 62.16724(a)).

Should the design capacity report indicate a capacity equal to or greater than 2.5 million Mg and 2.5 million m3 of solid waste a landfill can accept; then, an annual NMOC emission rate report must also be submitted within 90 days after the effective date of the Federal plan, and then every 12 months until the landfill installs a GCCS (40 CFR 62.16724(c)).

You may find a copy here on EPA’s website.

 

Contact your SCS project manager or for assistance. Follow us on Twitter, LinkedIn, or Facebook to receive EPA alerts and SCS Technical Bulletins, along with other news.

 

 

 

Posted by Diane Samuels at 6:00 am

SCS Engineers Expands Environmental Services in the Midwest

May 12, 2021

 

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.

Richard D. Southorn, PE, PG, SCS Engineers-Chicago

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 .

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

As your business grows, it might generate EPA defined hazardous waste

May 10, 2021

 

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.

  • Solid Waste is any solid, liquid, semi-solid, or contained gaseous materials abandoned or intended for disposal.
  • Hazardous Waste is a subset of solid waste considered hazardous due to its toxic, corrosive, reactive, or ignitable nature.
  • Listed Hazardous Waste is hazardous waste based on its chemical composition and use (regardless of testing results). Examples – used dry cleaning solvents, out-of-date pesticides, used paint solvents.
  • Characteristic Hazardous Waste is hazardous waste that is toxic, corrosive, reactive, or ignitable based on testing. Examples – contaminated soil where the source of contamination is unknown, spent acid or bases, waste paint and solvent mixtures of unknown composition.
  • A Generator is anyone or any company that generates hazardous waste,
    • Large Quantity Generator (LQG) – generates more than 1,000 kg (2,200 lbs.) of waste per month (depending on the materials, this is about two to five 55-gallon drums).
    • Small Quantity Generator (SQG) – generates more than 100 kg (220 lbs.) per month (less than one 55-gallon drum) but less than 1,000 kg.
    • Conditionally Exempt SQG (CESQG) – generates less than 100 kg per month.

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:

  1. Storing no more than 55-gallons of hazardous waste at any one Satellite Accumulation area (certain highly toxic chemicals are limited to 1 quart).
  2. Containers must be in good condition, compatible with the waste (e.g., no acids in metal containers), and kept closed unless transferring the waste to a storage container.
  3. Label all containers with “hazardous waste” and other terms describing the contents.
  4. Do not combine containers from different Satellite Accumulation areas, except in the hazardous waste storage area and after checking the labels.
  5. There is no time limit for storage within the Satellite Accumulation area as long as the volume is below the threshold for the type of waste.
  6. The accumulation start date applies only to the bulk waste containers in the hazardous waste storage area.

 

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.

 

Jim Oliveros of SCS Engineers, Florida.

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.

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

Renewable Solar Energy on Closed Landfills – A Win for Local Governments and Citizens

May 3, 2021

Ameresco solar project on a closed landfill. Courtesy of Ameresco.

 

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.

 

Slated to launch in 2021, the two Maryland projects provide value to their communities – lowering greenhouse gas emissions, providing renewable energy and environmental integrity while creating jobs and savings for taxpayers. That’s a win for Maryland and its citizens.

 

Solar Energy on Brownfields and Closed Landfills

 

 

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

SCS Technical Bulletin – EPA’s Request for Inactive CCR Surface Impoundments Information

February 4, 2021

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 https://www.scsengineers.com/publications/technical-bulletins/.

Our most recent Bulletin entitled EPA Seeks Feedback On Inactive Surface Impoundments at Inactive Electric Utilities summarizes the EPA’s request for comments and information pertaining to inactive impoundments at inactive facilities.

Operators and owners who may be affected by forthcoming decisions around inactive CCR surface impoundments include electric utilities and independent power producers who generate CCR within the North American Industry Classification System (NAICS) code 221112. Though the EPA states “other types of entities … could also be regulated” and advises those wanting to confirm if the regulation applies to them to read the applicability criteria and comment. Landowners with a legacy surface impoundment on their property purchased from a utility will want to review the proposed definitions closely.

SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.

Visit our website for more information.

 

 

 

 

 

Posted by Diane Samuels at 6:00 am