EPA

Comment on EPA’s Draft Interim Guidance on PFAS Destruction and Disposal – Deadline February 22

February 9, 2021

SCS Engiineers provides regulatory updates for industrial clients

EPA is releasing the interim guidance for public comment. The guidance provides information on technologies that may be feasible and appropriate for the destruction or disposal of PFAS and PFAS-containing materials. It also identifies needed and ongoing research and development activities related to destruction and disposal technologies, which may inform future guidance.

The interim guidance addresses PFAS and PFAS-containing materials including:

  • Landfill leachate containing PFAS.
  • Soil and biosolids.
  • Solid, liquid, or gas waste streams containing PFAS from facilities manufacturing or using PFAS.
  • Textiles, other than consumer goods, treated with PFAS.
  • Spent filters, membranes, resins, granular carbon, and other waste from water treatment.
  • Aqueous film-forming foam (for firefighting).
  • The interim guidance is not intended to address the destruction and disposal of PFAS-containing consumer products, such as non-stick cookware and water-resistant clothing.

The agency is also providing guidance on testing and monitoring air, effluent, and soil for releases near potential destruction or disposal sites. EPA’s interim guidance captures the significant information gaps associated with PFAS testing and monitoring and identifies specific research needs.

The interim guidance is intended to assemble and consolidate information in a single document that generally describes thermal treatment, landfill, and underground injection technologies that may be effective in the destruction or disposal of PFAS and PFAS-containing materials.

As further research and development occur on this issue, EPA will incorporate this increased knowledge into future versions of this guidance to help decision-makers choose the most appropriate PFAS disposal options for their particular circumstances. EPA will review and revise the interim guidance, as appropriate, or at least once every 3 years.

See the EPA website: EPA Interim Guidance on Destruction and Disposal of PFAS.

Comments must be received on or February 22, 2021.

Instructions: All submissions received must include Docket ID No EPA-HQ-OLEM-2020-0527 for this rulemaking. Comments received may be posted without change to the Federal eRulemaking Portal. You may send comments by any of the following methods:

  • Federal eRulemaking Portal: https://www.regulations.gov/ (EPA’s preferred method). Follow the online instructions for submitting comments.
  • Agency website: www.epa.gov/pfas. Follow the online instructions for submitting comments.
  • Mail: U.S. Environmental Protection Agency, EPA Docket Center, OLEM Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
  • Hand Delivery/Courier: EPA Docket Center, WJC West Building, Room 3334, 1301 Constitution Avenue NW, Washington, DC 20004. Open 8:30 a.m.-4:30 p.m. ET, Monday-Friday.
  • Comment to NWRA and SWANA (see below).

 

Industry Comments on EPA’s PFAS Draft Interim Guidance

 

According to Waste Dive, the document is the first such federal guidance on the destruction or disposal of PFAS or PFAS-containing materials. It describes the available science used in three major techniques: deep well injection, landfilling and thermal treatment. Acknowledging uncertainty about potential environmental effects, the EPA proposed the interim storage of PFAS-containing waste until further research can “reduce the uncertainties associated with other options.”

Industry groups such as the National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) said they are analyzing the document and discussing with their members, such as SCS Engineers what the interim guidance means for daily landfill operations. The trade groups will submit comments on the document by the Feb. 22 deadline.

 

 

 

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

EPA Webinar: Landfill Surface Emissions Monitoring and Measurement Virtual Workshop

January 28, 2021

EPA will host two virtual half-day sessions on Tuesday, January 26, and Thursday, January 28, 2021, to explore recent air emissions measurement and monitoring developments from municipal solid waste (MSW) landfills.

The sessions are designed to provide an opportunity to share and learn more about surface emissions monitoring and measuring technologies. This virtual workshop is open to the public, with the primary audience including MSW landfill owners/operators, federal and state regulatory agencies, and environmental consultants.

Register Here

If you have any questions, please contact Shannon Banner at or John Evans at .

Session II – Thursday January 28, 2021; 1:00 to 4:30 PM (EDT) 

The final rule applies to both major and area sources and contains the same requirements as the Emission Guidelines and New Source Performance Standards (EG/NSPS), promulgated in 1996. The final rule adds startup, shutdown, and malfunction (SSM) requirements, adds operating condition deviations for out-of-bounds monitoring parameters, requires timely control of bioreactor landfills, and changes the reporting frequency for one type of report.

The hazardous air pollutants (HAP) emitted by municipal solid waste (MSW) landfills include, but are not limited to, vinyl chloride, ethyl benzene, toluene, and benzene. Each of the HAP emitted from MSW landfills can cause adverse health effects provided sufficient exposure.

 

NSPS/NESHAP Compliance

 

 

 

 

 

 

 

Posted by Diane Samuels at 1:00 pm

EPA Webinar: Landfill Surface Emissions Monitoring and Measurement Virtual Workshop

January 26, 2021

EPA will host two virtual half-day sessions on Tuesday, January 26, and Thursday, January 28, 2021, to explore recent air emissions measurement and monitoring developments from municipal solid waste (MSW) landfills.

The sessions are designed to provide an opportunity to share and learn more about surface emissions monitoring and measuring technologies. This virtual workshop is open to the public, with the primary audience including MSW landfill owners/operators, federal and state regulatory agencies, and environmental consultants.

Register Here

If you have any questions, please contact Shannon Banner at or John Evans at . Register once for both sessions.

Session I – Tuesday January 26, 2021; 1:00PM to 4:30 PM (EDT)

Session II – Thursday January 28, 2021; 1:00 to 4:30 PM (EDT) 

 

The final rule is applicable to both major and area sources and contains the same requirements as the Emission Guidelines and New Source Performance Standards (EG/NSPS), promulgated in 1996. The final rule adds startup, shutdown, and malfunction (SSM) requirements, adds operating condition deviations for out-of-bounds monitoring parameters, requires timely control of bioreactor landfills, and changes the reporting frequency for one type of report.

The hazardous air pollutants (HAP) emitted by municipal solid waste (MSW) landfills include, but are not limited to, vinyl chloride, ethyl benzene, toluene, and benzene. Each of the HAP emitted from MSW landfills can cause adverse health effects provided sufficient exposure.

 

NSPS/NESHAP Compliance

 

 

 

 

 

 

 

Posted by Diane Samuels at 1:00 pm

U.S. EPA Landfill Surface Emissions Monitoring and Measurement Virtual Workshop

January 11, 2021

SCS Engiineers provides regulatory updates for industrial clients

EPA is hosting a free workshop in January on landfill monitoring and emissions. The workshops are scheduled twice, over half-day sessions. These sessions will include presentations highlighting the latest technological developments for monitoring and measuring landfill gas emissions.

Dates and Times: Register once for both sessions.

  • Session I – Tuesday, January 26, 2021; 1:00PM to 4:30 PM (EDT)
    • 1:00 to 1:15 – Introduction Day One and Workshop Details
    • 1:15 to 1:45 – EPA Presentation – Current Landfill Monitoring and Measuring Regulatory Requirements
    • 1:45 to 2:30 – Bridger Photonics
    • 2:30 to 2:40 – BREAK / STRETCH
    • 2:40 to 3:25 – Sniffer Robotics
    • 3:25 to 4:10 – Elkin Earthworks
    • 4:10 to 4:30 – Q&A and Closing
  • Session II – Thursday, January 28, 2021; 1:00 to 4:30 PM (EDT) 
    • 1:00 to 1:10 – Introduction Day 2
    • 1:10 to 1:55 – Scientific Aviation
    • 1:55 to 2:40 –  GHGSat
    • 2:40 to 2:45 – BREAK/STRETCH
    • 2:45 to 3:30 – mAIRsure
    • 3:30 to 4:20 – LI-COR
    • 4:20 to 4:30 – Closing

 

Register Here

If you have any questions, please contact Shannon Banner at or John Evans at .

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

SCS Technical Bulletin: A Summary of the CCR Final Rule Revisions

September 25, 2020

electric utilities and powerplants - scs engineers

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 summarizes the

CCR Rule Revisions – A Holistic Approach to Closure Part A: Deadline to Initiate Closure and Enhancing Public Access to Information

 

This Bulletin provides information on these revisions, as follows:

  • Surface Impoundment Alternative Closure Provision Timelines
  • Unlined Surface Impoundment Requirements
  • Unlined Surface Impoundment Cease Receipt of Waste and Initiation of Closure Deadline
  • Annual Groundwater Monitoring and Corrective Action Report Requirements
  • Requirements for Publicly Accessible CCR Internet Sites

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am

How does your state expect you to submit EPCRA Tier II Reporting?

September 14, 2020

The Emergency Planning and Community-Right-to-Know Act (EPCRA) was enacted by Congress to assist local communities in protecting public health by requiring facilities to file an annual EPCRA Tier II Report, identifying hazardous chemical inventories maintained at the facility. Submitting Tier II Reports allows the local emergency personnel to be aware of the chemicals that are present within facilities in their jurisdiction, and prepare for and respond to chemical emergencies.

 

It is extremely important to verify the submittal method in your state.

The annual federal deadline for submitting Tier II Reports is March 1st (more to come on
this deadline). Facilities are required to report any chemicals, which are included within the OSHA Hazard Communication Standard (29 CFR 1910.1200). A list of EHSs and their TPQs can be found at 40 CFR 355, Appendix A. The EPA has compiled a “List of Lists” which provides a consolidated list of chemicals that are subject to EPCRA Tier II reporting along with their Threshold Planning Quantities (TPQ). The TPQ is the amount of chemical kept on-site above which you must file a Tier II. It is important to note that ammonia has a Tier II reporting threshold of 500 pounds.

  • Each facility maintaining chemical inventories, as described in the article are required to submit an annual Tier II Report to the following agencies:
  • State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and
  • The fire department having jurisdiction over the facility.

Some states require that Tier II forms be submitted electronically, while other states may require hard copy submittals. Still, others require both digital and printed submissions.

Keep reading to find out more from Travis Weber at SCS Engineers, Tracer Environmental Practice…

 

 

 

Posted by Diane Samuels at 6:00 am

Show Me the Money! Brownfield Redevelopment for Affordable Housing CA Conference

September 12, 2020

Brownfields, particularly those in urban infill areas, can be successfully redeveloped into housing and other productive uses with significant benefits to the surrounding communities. Redeveloping brownfields is also an important strategy in addressing California’s affordable housing crisis.

However, funding for brownfield redevelopment falls well short of the need, which is exacerbated by the COVID-19 pandemic and resulting impacts on budgets. But there is hope. Proposed legislation and budget requests for new sources of funding for brownfield redevelopment are proposed in excess of $100M. These policy shifts and resulting funding would make a big difference.

At the upcoming California Land Recycling Conference, several experts from the public and private sectors will share their insights and the latest information about these potential funding sources and opportunities for affordable housing and infill sites in California.

Moderated by Dan Johnson, Vice President & National Partner for Brownfield Redevelopment at SCS Engineers, the panelists are:

  • Janae Davis, Deputy Executive Director of the California Pollution Control Financing Authority
  • Diane Barclay, Assistant Deputy Director and UST Cleanup Fund Manager with the State Water Resources Control Board
  • Markus Niebanck, Principal with Amicus Strategic Environmental Consulting.

The conference is scheduled for Sept. 22-24, 2020. To join this interactive session, Sept. 23 from 2:15 to 3:00 PST, register at https://bit.ly/2FoWI89. Non-profit and student tickets are $25, government tickets are $50, and General Admission is $75.

 

Grant Application Help

 

 

 

 

Posted by Diane Samuels at 4:38 pm

Running Landfill Operations While Facing EPA Regulation Limbo, Staff Shortages, and Funding Dilemmas

August 3, 2020

comprehensive landfill permit-design-operate-build-monitor

Being a landfill operator or owner is a demanding job. Your position requires knowledge of engineering, biology, chemistry, business, technology, and psychology. Most people don’t realize the complexity of landfill operations and the systems, personnel, and equipment that keep everything in balance. That’s okay; it’s part of the job too. The public generates trash, and it is picked up, reused, recycled, or landfilled as communities dictate.

Right now, landfill operations are more challenging than ever – so we’re providing a bit of help from our SCS website library. We hope it helps, but you can always reach out to your project manager for additional assistance.

Strategies for EPA Regulation Limbo

Landfill owners and operators remain in a state of regulatory limbo. Some sites are complying with the New Source Performance Standards (NSPS) under Subpart XXX and dealing with the duplicate requirements from Subpart WWW and other issues. Several states have approved Subpart Cf Emission Guidelines (EG) rules, so landfills in those states must begin to comply with those state rules. Several other states have proposed state plan approvals and could see approved EG rules issued soon, as in Virginia. When EPA issues the federal plan for the EG, all of the remaining landfills in states without approved state plans will have to start to comply. This will put all NSPS/EG-applicable landfills into the same boat with the existing Subpart XXX sites.  In addition, landfills are figuring out how the new National Emission Standards for Hazardous Air Pollutants (NESHAPs) rule overlays on top of the NSPS/EG requirements.

During this period of limbo, where multiple overlapping regulations exist, certain public and private landfill owners within the solid waste industry have endeavored to take a unified and consistent stand on compliance strategies with guidance coming from the Solid Waste Association of North America (SWANA) and the National Waste and Recycling Association (NW&RA). Gabrielle Stephens, Cassandra B. Drotman, and Patrick Sullivan of SCS provide a regulatory update and compliance strategies in their paper Uncertainty EPA has Created with New NSPS XXX and Cf Rules

Staff Shortages and Funding Dilemmas

Many of our clients are in their annual budget period. Needless to say, nearly all municipalities have concerns about the upcoming fiscal year expectations and anticipated medium-term impacts of COVID-19 on local government operations and revenue streams. They have shared goals to:

  • Avoid municipal or utility service interruptions
  • Continue to provide services to customers who can’t afford to pay
  • Predict impact on property, earnings or sales tax revenues
  • Estimate changes in water usage or waste generation
  • Address the longer-term financial impacts of staffing changes, prolonged vehicle/equipment replacements, and postponing or increased borrowing for capital projects.

In response, our team of economists is helping our clients prepare for Fiscal Year 2020/2021, with a Micro-analysis for the near-term (1-2 year) budget/operational impacts. It’s free, and you’ll get results in 2-3 days.

SCS is offering free webinars to discuss revenue diversification alternatives, realistic cost projections, and funding opportunities. We will announce the first webinar in the next week, but if you’d like to get started now contact the  SCS Management Services® Lead here for a private session.

 

 

 

 

 

Posted by Diane Samuels at 6:03 am

Transforming and Revitalizing Communities by Cleaning Up Brownfields

July 17, 2020

Partial Reprint of EPA Press Release

Over the past three years alone, EPA has assessed 6,572 properties, completed cleanups at 638 properties, and made 2,900 properties ready for anticipated reuse. Over this same period, more than 43,000 jobs have been leveraged as a result of Brownfields’ actions.

EPA recently announced the selection of 155 grants for communities and tribes totaling over $65.6 million in EPA Brownfields funding through the agency’s Assessment, Revolving Loan Fund, and Cleanup Grant Programs. Many of the communities and tribes selected can potentially assess or clean up brownfield sites in census tracts designated as federal Opportunity Zones.

“Without redevelopment opportunities, urban and rural communities – even those with deep historic roots – can eventually wither,” said OLEM Assistant Administrator Peter Wright. “Brownfields remediation and revitalization support communities by investing in the redevelopment of existing properties in the community.”

Since EPA’s Brownfields Program began in 1995, it has provided nearly $1.6 billion in Brownfield funding to assess and clean up contaminated properties and return blighted properties to productive reuse.  EPA’s Brownfields funding has leveraged more than $32.6 billion in cleanup and redevelopment from both public and private sources, which in turn has produced more than 167,000 jobs. This is an average of nine jobs per $100,000 of EPA investment and more than $17 in private funding for each dollar of EPA Brownfield grant funding.

Brownfields grants have been shown to:

  • Increase Local Tax Revenue: A study of 48 Brownfields sites found that an estimated $29 million to $97 million in additional local tax revenue was generated in a single year after cleanup. This is two to seven times more than the $12.4 million EPA contributed to the cleanup of these sites.
  • Increase Residential Property Values: Another study found that property values of homes near revitalized Brownfields sites increased between 5 and 15 percent following cleanup.

 

Background:

A Brownfield is a property for which the expansion, redevelopment, or reuse may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant. The Brownfields program empowers local leaders and communities to transform underused and distressed properties into community assets across America. Brownfields funds assess and cleanup vacant, underused, and potentially contaminated properties so that property can be reused as housing, recreation, and open space, health facilities, social services, or commercial sites. There are estimated to be more than 450,000 Brownfields in the United States.

For more information on successful Brownfields program applications, site revitalization, and success stories nationwide visit Brownfields and Voluntary Remediation. If you’d rather jump right into a few success stories, click on these below:

Locate a Brownfields and remediation expert near you – SCS Staff

 

 

 

 

Posted by Diane Samuels at 6:00 am