Since the 1990s, USEPA has provided risk-based Regional Screening Levels (RSLs) to assist in evaluating environmental monitoring and contaminant levels – e.g., in soil, air, and water at residential and industrial properties. EPA periodically updates the RSL tables to reflect new contaminants of concern and new chemical toxicity data. The May 2022 RSL tables have been expanded to include 14 per- and polyfluoroalkyl substances (PFAS). PFAS are a large family of emerging contaminants that are garnering significant interest due to their significant toxicity and widespread use in industrial and consumer products such as fire-fighting foam, fabric treatment, and some food packaging. The latest EPA RSL tables are available at: https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables
Additional info regarding ongoing efforts to address and treat PFAS are available by searching this website: https://www.scsengineers.com/ and then using the filter to narrow down returns to your interests.
Join EPA, SCS Engineers, and the GWPC for the 2022 Annual GWPC & UIC Conference in Salt Lake City, from June 21 through June 23. This year’s event features two experts from SCS, Kacey Garber and Stephanie Hill. In today’s blog, we take a dive into their presentations, where both women use case studies to highlight safely using deep injection wells, and what can happen during operations to plan for more sustainable operations. Learn more here.
Thursday, June 23 at 8:30-10:00 Class VI UIC
“Sensitivity of Aquifer Chemistry to Changes in Carbon Dioxide Partial Pressure: Implications for Design of Groundwater Monitoring Protocols,” Kacey, Julie O’Leary, and Charles Hostetler are all with SCS Engineers. The team will discuss Carbon Sequestration and Storage (CSS) solutions. Great care is taken in the design and operation of the injection of carbon compounds to ensure that the sequestration is effective and permanent. Each injection site also has permitting requirements for groundwater monitoring in any overlying aquifer as a protective measure. Because the duration of the injection and sequestration periods are long, it is essential for CSS projects to have a cost-effective groundwater monitoring program with a robust sensitivity to detect any leakage.
In this case study, the SCS team has examined the sensitivity of aquifer chemistry (major and minor cations and anions) to the partial pressure of carbon dioxide using an aqueous speciation/solubility/sorption model. They examined a number of hydrochemical facies, both natural and synthetic, to determine which geochemical parameters are most likely to be affected by changes in the partial pressure of carbon dioxide. The team anticipates that the regulatory framework and practice for CSS will be similar to that of Municipal Solid Waste (MSW) and Coal Combustion Residue (CCR) disposal sites. Prior to the injection of carbon compounds, the overlying aquifer is characterized and background values for key parameters are established. During the injection and post-injection phases of the project, there is periodic monitoring of the groundwater parameters, which they anticipate will be compared to the established background. When Statistically-Significant Increases (SSIs) are found, an Alternate Source Demonstration (ASD) will have to be prepared that attributes the SSIs to the CSS operation or to some other source. By establishing a groundwater monitoring protocol that is specific to the site, sensitive to changes in the partial pressure of carbon dioxide, and relative insensitive to natural variability and hydrochemical facies changes, optimal and cost-effective groundwater protection can be implemented.
Kacey Garber is an experienced groundwater project manager for active and closed landfills, 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 workgroups. Ms. Garber has a Master’s in Geoscience from the University of Iowa, and a BS in Geology from Illinois State University Her field experience includes collecting groundwater, surface water, landfill leachate, industrial and municipal wastewater, and soil; oversight of groundwater monitoring well installation; logging and sampling soils for well-drilling operations; groundwater well maintenance and development; inspection of final landfill covers for post-closure care; and routine wetland monitoring and delineation activities.
Thursday, June 23 at 10:30 – 12:00 Class I UIC
“Microbially Influenced Corrosion in Injection Wells: A Case Study in a Class I Well for Coal Combustion Residuals,” with Stephanie Hill. Stephanie will discuss microbially influenced corrosion (MIC) is known as a direct cause of mechanical integrity failure in injection wells. While premature failures of expendable components, such as casing and packers, are inconvenient and expensive, this is not the only reason to proactively address downhole biological issues. Stringent control and mitigation of biological activity are imperative to minimizing borehole fouling and subsequent plugging of an injection reservoir. If left untreated, a well’s long-term reservoir health and operational efficiency may be jeopardized.
This presentation will summarize a case study of MIC-related failure in a Class I injection well used for leachate disposal from a coal combustion residuals facility. The well failed to maintain internal mechanical integrity just six months after being commissioned. We’ll walk through the investigation process, which includes annular pressure testing, downhole caliper logging, casing thickness detection, injection fluid analysis, and metallurgical analysis to identify the cause of failure. Following the replacement of the injection casing and packer, injection tests were conducted to assess the potential impacts of MIC on the reservoir’s ability to accept injected fluids. A proactive disinfection plan was customized based on the unique investigative results and implemented to prevent future MIC-related issues.
Stephanie Hill is a hydrogeologist, program leader for SCS Engineers’ Carbon Sequestration and Deep Well Injection practice, and licensed Professional Geologist. She earned a BS in Geosciences at the University of Texas, emphasizing hydrogeology and geomorphology. Stephanie’s early career focused on environmental compliance for mineral and fossil fuel industries at the Texas Commission on Environmental Quality (1996 to 2000) and the Railroad Commission of Texas (2000 to 2012). Currently, she leads a team of geologists and engineers to advise SCS clients of various industries on geologic storage options for carbon neutrality and disposal solutions for liquid residuals.
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.
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.
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:
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:
For more information on the public listening sessions:
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.
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.
Partial Reprint from EPA Announcement
The U.S. Environmental Protection Agency (EPA) is announcing the selection of 151 communities to receive 154 grant awards totaling $66.5 million in Brownfields funding through its Multipurpose, Assessment, and Cleanup (MAC) Grants.
This funding will support underserved and economically disadvantaged communities across the country in assessing and cleaning up contaminated and abandoned industrial and commercial properties. Approximately 50 percent of selected recipients will be receiving EPA Brownfields Grant funding for the first time and more than 85 percent are located in or serving small communities.
The grant announcement includes:
The list of the fiscal year 2021 applicants selected for funding is available here: https://www.epa.gov/brownfields/applicants-selected-fy-2021-brownfields-multipurpose-assessment-and-cleanup-grants
Please spend some time with our experts as they help you negotiate funding, regulatory compliance, and helpful tools that will help your community prepare to remediate brownfields and other properties with a past into affordable housing, mixed communities bolstering economic development, stadiums, recreation facilities and parks, logistics centers…
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.
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:
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.
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.
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:
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.
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:
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.
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.
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.